Not automatically. Joint sessions are used strategically when they will advance resolution. In many employment and personal injury matters, a caucus-forward approach is more productive.

Briefs should focus on key evidentiary disputes, damages analysis, and negotiation history. Confidential addenda discussing underlying interests and true risk assessments are strongly encouraged.

Yes, but only when appropriate and typically when the parties have exhausted direct negotiation. A proposal is not a default endpoint, but a strategic tool to bridge a final gap.

Yes. Multi-party matters often require additional pre-mediation organization to ensure all stakeholders are aligned on the procedural approach before the session begins.

Both. In-person mediations are conducted throughout the San Francisco Bay Area. Virtual mediations are hosted on dedicated, secure Zoom platforms with private breakout rooms.