- 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.
- 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.