2"Unless required to do so by applicable law and in the absence of any agreement of the parties to the contrary, a party shall not in any manner produce as evidence in any judicial, arbitration or similar proceedings:
any documents, statements or communications which are submitted by another party or by the Neutral in the ADR proceedings, unless they can be obtained independently by the party seeking to produce them in the judicial, arbitration or similar proceedings;
any views expressed or suggestions made by any party within the ADR proceedings with regard to the possible settlement of the dispute;
any admissions made by another party within the ADR proceedings;
any views or proposals put forward by the Neutral; or
the fact that any party had indicated within the ADR proceedings that it was ready to accept a proposal for a settlement.