Mediation has many components.  The Attorney’s mediation summary is an invaluable tool to the mediation process. Not only does the summary focus on the critical issues, but it can save your client time and money. Often, counsel will submit copies of the pleadings with a statement that the issues are self-explanatory. That’s great, but if you can direct me to the issues more efficiently, I will spend less time in preparation. I also think it’s a great idea to point out specific concerns that you may have regarding your case. Remember, the mediation summary is confidential and will not be disclosed to the other side. Since I am not the ultimate arbiter, a mediation summary which reads like a brief or a memorandum of law may not be the most effective means of communication with the mediator.


To quote Jerry McGuire, “Help me help you.”


Attorneys Rod B. Neuman and John R. “Jack” Bello, Jr., are Florida Supreme Court Certified Circuit Court Mediators.