Do you wonder if the mediator understands your case? Including a “Cliffs Notes” face page on top of the detailed brief provides a valuable road map for you and the mediator. I appreciate counsel who provide me with this visual aid as I get up to speed on the case.


1/ Clear Chronology
1/6/15: P hired
1/28/15: 1st write up
2/2/15: 2nd write up


2/ List of Key People by Name, Title and Brief Description
John Smith: P’s first supervisor 2012-termination
Mary Klein: HR Dir: recommended termination
Connie Wong: EE Relations recommended suspension
Ally: P’s co-worker witness to incident


3/ Table of Tabbed Exhibits in Order in Which They Appear in Brief
Exhibit 1: Hiring contract
Exhibit 2: Policy manual re religious holidays
Exhibit 3: Warning memo
Exhibit 4: Investigation Results
Exhibit 5: Termination letter


4/ Threshold Issues in Dispute
– Was separation a termination or a voluntary quit?
– Adequacy of not


5/Key Damages Issues In Dispute
– Will medical situation override absence of mitigation?
– Was separation a termination or a voluntary quit?

  • Presentation Skills for Mediation
  • How to Move and Influence Your Mediator
  • Is There a Difference Between “Lying” and “Deception” in Mediation
  • Improve Your Outcome at Mediation
  • What are they willing to Do in Mediation?