Mediation memoranda
  • Memos addressing the topics in Rule 16.1 (c) are helpful.
  • Shorter is almost always better than longer.
  • Whenever possible, your memo should be submitted a week before the mediation.
  • Absent agreement between counsel, memos should be exchanged. Please note in your memo whether or not a copy has been provided to the other side.
Telephone conference
  • Mark may ask to speak with you on the phone before the mediation.
  • Mediations are normally held at the office of one of the attorneys.