What sophisticated parties expect, written down.

Counsel calls or submits the inquiry form. I return a conflict-check questionnaire within one business day. The questionnaire covers parties, related entities, counsel, insurers, and key witnesses.

I give no substantive response before the conflict check completes. Where a conflict exists, I say so and decline. Where it does not, the engagement step begins.

I issue an engagement letter covering fees, cancellation policy, confidentiality, the no-subpoena clause, mediator immunity, and scope of the work. Both sides sign before pre-mediation calls begin.

Engagement is effective only when both sides have signed. I place calendar holds on receipt of the signed letter and the deposit.

Each side delivers a mediation brief, typically five to fifteen pages plus exhibits, seven to ten days before the session. Briefs may be exchanged or kept confidential, at the parties’ election.

A thirty- to sixty-minute pre-mediation call with each side’s counsel is where I learn what the brief did not say. By the time parties convene, the working theory is on the page.

A short joint opening, then sustained caucus. I move between rooms with reframings, questions, and incremental movement. What is told to me in caucus stays in caucus unless authority to share is requested and granted.

Parties are not required to be in the same room. Where one side prefers individual sessions, I run the mediation as a shuttle and meet with each party privately. The format is settled in the pre-mediation calls and confirmed before the day.

I do less speech-making and more listening. The first hour is for understanding what each side actually needs; the middle for testing positions against alternatives; the close for finding the shape of the agreement.

When settlement is reached, I draft a term sheet that the parties sign in the room. The term sheet is enforceable on its own terms; it is not a placeholder.

Counsel for each side draft the long-form agreement in the days that follow. I remain available during that window to clarify the term sheet’s intent and to help bridge drafting friction.

Where settlement is not reached, the file does not close. I remain engaged for follow-up calls, written mediator’s proposals, and reconvening where the parties wish.

Where settlement is reached, I stay available through long-form drafting and, where useful, through any consent-order or court-approval process that follows.