Mediation Submissions

In preparation for the scheduled mediation, the attorneys for each party should submit to me a letter along with important attachments (if needed) which contains the following:

  1. An analysis of key issues involved in the litigation.
  2. A description of the strongest and weakest points in your and your opponent’s case, both legal and factual.
  3.  The status of any settlement negotiations, including the last settlement proposal made by you and to you.
  4. A settlement proposal that you believe would be fair.
  5. A discussion of any obstacles to settlement, such as personality conflicts, outside influences and policy considerations.

This letter should be should be submitted to me several working days before the mediation. Please convey your mediation materials by email to me at If you have questions regarding your submission, please contact me to discuss. All parties and (if defendant is insured) adjusters with authority must attend. If an adjuster cannot attend, one with authority must be readily available by phone.

If there are any third party liens or subrogated interests, please determine the amount with certainty before the mediation. Third party claims personnel should be available by telephone if these interests need to be considered in order to effectuate settlement.

All communications made in connection with the mediation are confidential and will not be disclosed to anyone. Any documents submitted for the mediation will be maintained by me and will be destroyed after the mediation.