Mediation Attendance

Mr. Saler strongly encourages you to arrange for the appropriate individuals to attend the mediation session and to notify him who will be participating. The mediation is most likely to lead to a resolution of the matter when the actual decision makers and involved parties are present. Such persons may include a plaintiff's family member, a lien claimant's representative, a claims professional, or an insured being defended under a reservation of rights. If a client or client representative wants to participate by telephone, their legal counsel should contact all other counsel to obtain their consent. If a conflict arises over someone's request to be available by telephone, if called upon Mr. Saler will intervene to resolve it.

Confidentiality is strictly protected. All mediation participants will be required to sign an agreement which, among other things, maintains the confidentiality of the mediation.

Pre-Mediation Telephone Calls

Mr. Saler encourages you to call or e-mail him to discuss whether a particular case is appropriate for mediation before scheduling a session. Once a case is scheduled, you can call or e-mail him to discuss any issues or concerns you may have about the mediation. Contacting the mediator is not an ex parte communication.

Guidelines for Mediation Briefs

Mr. Saler strongly encourages you to send him a mediation brief. Mr. Saler also finds that he is better prepared and the mediation session takes less time if he receives beforehand copies of key medical records, reports by treating physicians and defense medical examiners, medical bills, photographs, diagrams, Traffic Collision or expert reports, employment records, contracts, executed real estate disclosure forms, pleadings, motions, excerpts of deposition testimony, or anything else you believe will assist him in preparing for the session.

Mr. Saler suggests you exchange your brief with all other legal counsel. You may also submit a supplemental confidential letter if you want to communicate information or writings solely to the mediator.


You can conveniently transmit your submission by facsimile (818) 379-9554, or send it to Mr. Saler's email address alan@alansaler.com. His computer software programs include Word Perfect, Word and Adobe so he should be able to read or view any scanned materials. If your brief or attachments total more than twenty-five pages, submit them by mail. Mr. Saler prefers that he receive all pre mediation submissions at least two days before the session so he has adequate time to prepare.