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Mike Ludwig

Employment Mediator

Mediation Process

Availability and Scheduling

Please email Mike directly at mike@mikeludwig.com to inquire about his mediation availability. You also can use the “Connect” button below to inquire about availability.

When you are ready to book a mediation, please send an email to mike@mikeludwig.com, with a cc to all counsel, and include your agreed-upon date, the case name and type, the names and contact information for all counsel, and the agreed-upon mediation fee split. A Scheduled Mediation Notice will issue shortly thereafter.


Mediation briefs will be treated as confidential unless the parties specify otherwise. The participants are encouraged to be mindful of what information the mediator can or cannot share with the other side; the mediator will not share information provided in confidence without confirmation that the information can be communicated to the other side.

Mediation Briefs

Mediation briefs should be submitted a week before the mediation session to allow time for counsel to address any questions from the mediator that might arise from the briefs. Effective mediation briefs help the meditator understand the nature and nuances of a dispute prior to the mediation date so the mediation session itself can be devoted to getting to the heart of the dispute and focusing on how to resolve it. The parties can decide whether they want to submit confidential mediation briefs or to exchange them.

Following receipt of the briefs, Mike may schedule pre-mediation calls with counsel, and counsel also may request such calls be scheduled when they believe it would be helpful.


All counsel and parties should plan to participate in the mediation session. Any issues with respect to the availability of a party, decision-maker, insurance adjuster, or the like should be discussed with the mediator beforehand. The mediation session generally will be scheduled to begin at 10 am Pacific Time. All participants are requested to be prepared to stay with the process for as long as is required the day of the mediation to bring the matter to a successful resolution.


Mediation sessions generally are conducted virtually, with a Zoom link that will be provided when the mediation is scheduled. This facilitates participation by individuals who are geographically dispersed. Mike also can conduct the mediation in the office of counsel for any of the parties. If necessary, Mike can provide a comfortable location for the mediation for an additional fee.


The mediation rates are:

  • Single-plaintiff cases: $9,500
  • Class/PAGA/collective actions: $11,000

There are no administrative fees. The mediation rates are all-inclusive and cover preparation time, pre-mediation phone calls when helpful, all time that is required the day of the mediation, local travel if necessary, and reasonable follow-up. Half-day mediations for single-plaintiff cases are $6,000, which includes up to a four-hour mediation session.

Payment of the mediation fee is required to hold the mediation date, and the fees are fully refundable if the mediation is canceled at least three weeks before the scheduled date.