Guidelines & Schedule
Mediation can be one of the most effective investments of time and effort. These guidelines are provided to help us make the most of our time together.

Location & Logistics
Mediations are conducted at one of the attorney’s offices. Please determine which office will be most convenient and allow a conference room or office for each party to caucas. In addition, the hosting office provides coffee and drink service for the other parties. Please be at the office at least 5 minutes before the mediation is scheduled to begin so that the mediation can begin on time.

Mediation Briefs & Forms
Mediation briefs are recommended. To aid you in preparing a summary or brief, you may use the attached form. Generally, the best practice is for counsel to consider preparing a brief to be exchanged with opposing counsel, and a supplemental "confidential" brief to be provided only to Linda. Linda recommends that clients be provided with opposing counsel's brief, as well as their own, in advance of the mediation, so that clients can be prepared as well as possible to discuss the concerns which are likely to arise at the mediation. Briefs are requested five business days before the date scheduled for the mediation. All parties must sign the agreement to mediate before the mediation begins. If you plan on preparing your own settlement document to bring to the mediation, at the very least it must have the language provided in Linda’s sample settlement agreement.

Attendance at the Mediation
Linda recommends that, before the mediation, counsel discuss their plans regarding who will, and will not, be attending the mediation. Nothing is worse than a surprise. Generally, mediations work best when more, rather than fewer, people attend. The structure of the mediation (including the sequence and timing of joint sessions, private caucuses and attorneys-only caucuses) can be adjusted to meet the needs of the participants. Linda is available for pre-mediation telephone consultations and conference calls to help with any questions that may arise in this process.

To Schedule a Mediation
Please call our offices at 972-416-3652 or send an email to linda@lindaswindling.com.