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Mediation Agreement

(applicable to all ADR proceedings other than Arbitration):

We require an Agreement to Mediate/Confidentiality Agreement, signed by all parties and their counsel, at least 10 days prior to the scheduled hearing.

Where a hearing is scheduled on shortened time, this Agreement shall be returned as soon as reasonably possible prior to the hearing. This Agreement may be modified, at the discretion of the neutral, to meet the needs of each case.

Click Here MediationAgreement.pdf to download a copy of our Mediation Agreement form. You will need a pdf reader to open the document. (download Adobe Acrobat Reader for free)


Briefs may be served via fax, electronic mail or U.S. post. Please confirm receipt of briefs served via fax or e-mail.

1) Mediation, Neutral Evaluation, Special Settlement Hearings and Discovery Disputes

For all litigated matters where parties are represented by counsel,  a brief written statement is requested from counsel prior to your hearing. This is intended to be an informal and confidential statement of the facts, issues, damages, status of discovery and positions of the parties. It may be in letter, memo or pleading form and may be faxed or mailed. Service on opposing counsel is optional, but not recommended.

2) Arbitration

Brief's are required 10 days prior to the scheduled hearing date. Although there is no limit on length, it is recommended that a brief not exceed 10 pages, exclusive of exhibits. They shall contain a concise statement of the facts, an outline of all issues to be decided through arbitration and the supporting legal arguments and a specific statement of damages. They should also include a list of all witnesses expected to testify at the arbitration and an estimate on the amount of time needed for each. Service on opposing counsel is mandatory, and must be completed at least 5 days prior to the scheduled hearing date.

Location of Hearings

For your convenience, hearings are held at at the office of counsel for one of the parties, at the "ARC" offices in either Century City or Downtown Los Angeles, the offices of the San Fernando Valley Bar Association (in Woodland Hills) or at any other appropriate and centrally located facility in the Southern California area or elsewhere, upon request of all parties.


Continuances are liberally granted at no charge, as time and availability permit, when requested up to 10 days prior to the scheduled mediation date.

Hearings taken off calendar by a party or his/her attorney within 10 days of the scheduled hearing date, barring exigent circumstances or settlement, will be subject to a cancellation fee. Unless otherwise agreed, the party causing the cancellation shall be responsible for the payment of the fee.

If the required documents have not been received at least 10 days prior to the scheduled session and other arrangements have not been made with the neutral, your session may be taken off calendar until after the requested documents are received, and will then be rescheduled at the neutral's discretion.

Appearance of Parties

The physical presence of all parties and their attorneys is expected at the scheduled session, unless previously excused at the discretion of the mediator. Please note that although Insurance Adjusters are not technically parties, they are considered parties for purposes of mediation.

If there is any other person (i.e. spouse of a party, family member, friend, witness, etc.) whose opinion, knowledge of the matter or authority is important to a participant in the session or would have an impact on the outcome of our mediation discussions, please notify us immediately, so that we may discern whether their presence should be requested as well.


Click here to view American Arbitration Association Code of Ethics

Click here to view the California Dispute Resolution Council (CDRC) Standards of Practice for California Mediators.

Quick Jumps

» Mediation Agreement
» Briefs
» Location of Hearings
» Continuances
» Appearance of Parties
» Ethics

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