Upon booking, I will reach out with details about confidentiality, fee split, and how to make payment.
I like to have a brief pre-mediation call with each side within a week of mediation. I will reach out 2 weeks before mediation to schedule that call.
My other requests in advance of mediation are simple and flexible, and designed to maximize our time together:
Please get me a brief mediation statement that focuses on the factual strengths and weaknesses in your case. There is no need to include basic employment law. If, however, there is a unique legal issue, please feel free to include a legal overview. It is also helpful for me to understand any subtle dynamics at play and, for class or PAGA actions, I would like to know if there are any related cases.
I would like to see your most helpful documentary evidence in advance of mediation. I encourage you to share these documents with the other side, so we are all talking about the same universe of key evidence.
If there have been any depositions taken, I would like to see the transcripts. If the court or arbitrator has made any substantive orders, I'd like to see them (not the underlying papers, just the orders).