Pre-Mediation Preparation

Pre-Litigation Mediation

Parties are asked, but not required, to submit a brief summary of their position in the dispute, 2 days in advance. Relevant supporting materials are also useful.

Court-Annexed Mediation

The success of court-annexed mediation can be enhanced by preparation of the mediator. Therefore, prior to the day of mediation, counsel will be asked, but not required, to send the following materials:

  • The latest substantive pleadings.

  • A brief, concise summary of the case and the party's positions.

  • Any pending dispositive motions.

  • A summary of legal issues, along with copies of supporting cases, regulations and statutes, appropriately highlighted.

  • A brief summary of settlement negotiations.

It has been our experience that the likelihood of resolution is directly proportional to the preparation of the attorneys, the parties and the mediator.

The reading of these materials is included in the fee for mediation.

 

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