Before Your Online Mediation

Once we've been engaged, we need your careful attention to the following. You'll be submitting a number of documents to Carolina and Karl before your Online Mediation begins. Feel free to use email, postal mail, or an overnight delivery service.

• If you use email, send it to Carolina and be sure to copy Karl.

Within a Week of Confirming Your Engagement

1) Verify there are no conflicts of interest.

2) Estimate the number of people who will be attending for your team and email or phone Carolina with that number.

Karl expects all parties will be in attendance at the Online Mediation or have a representative present who knows the entire case well and has full settlement authority.

2 Weeks Prior to Your Online Mediation

1) Discuss the case with Karl by phone. To avoid telephone tag, please feel free to book a conference call here.

If there are issues not immediately apparent that could impede settlement, including insurance coverage issues or particularly sensitive interpersonal relationships, they need to be identified in this call.

2) Submit to Carolina a list that identifies all attendees for your team.

3) Review our payment policies and forward them to your client.

We expect to receive payment before your Online Mediation begins. If you must cancel after you have engaged us, we will need 24 hours notice. See details about cancellation here.

At Least 3 Days Prior to Your Online Mediation

1) Submit your written pre-mediation statement and any other materials you believe Karl needs to review in order to understand the disputed issues.

2) If your assistants want help thinking through what needs to be setup, they need to call Carolina at least three days prior to your mediation with their questions.

Karl will tell you he will read anything you send but he prefers you send helpful information about the case and a written summary of any thoughts you think will help him understand the case better. These are documents Karl finds most helpful:

• A short objective, footnoted case-summary of the dispute (history, background, past offers, etc.)
• Highlights of crucial depositions and documentary evidence with explanatory notes from the attorneys
• Confidential comments that don't appear on the face of the record about personalities or impediments to settlement
• MSJ briefs, briefs on important motions (e.g. Daubert), other briefs on important legal issues
• Graphics, pictures, tables or slideshows that illustrate key aspects of the dispute

Next: What to do during your Online Mediation