Mediation Process
Availability & Scheduling
To inquire about availability or schedule a mediation, please contact Mike’s case manager, Ashley Geller, at mediate@mikeludwig.com. You also can use the Request Availability Form.
When you are ready to book, please provide a preferred date (and a backup), along with the case name and type, counsel contact information, and the agreed-upon fee split. A Scheduling Notice will be circulated promptly upon confirmation.
Confidentiality
The mediation process is confidential to the fullest extent permitted by California law. Mediation communications, settlement discussions, and materials prepared for the mediation are protected from disclosure, subject to applicable legal exceptions. Mediation briefs will be treated as confidential unless the parties specify otherwise.
Mediation Briefs
Mediation briefs should be submitted at least one week before the mediation session. Early submission allows time for the mediator to review the materials, identify any issues requiring clarification, and address questions with counsel before the mediation date.
Effective mediation briefs help the mediator understand the facts, legal issues, and practical considerations underlying the dispute so that the mediation session can focus on meaningful settlement discussions and resolution.
The parties may choose whether to exchange mediation briefs or submit them on a confidential basis.
After reviewing the briefs, Mike may schedule pre-mediation calls with counsel. Counsel are also encouraged to request a pre-mediation call whenever they believe it would be helpful.
Participation
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.
Location
Mediation sessions are generally conducted via Zoom. Upon request, Mike is available to conduct in-person mediations at counsel's office or another mutually agreeable location.
Rates
To inquire about our rates, please email our case manager, Ashley Geller, at mediate@mikeludwig.com.
Our mediation rates are fixed fees that are all-inclusive and cover preparation time, pre-mediation phone calls when helpful, all time required on the day of the mediation, local travel when necessary, and reasonable follow-up if needed. There is no administrative fee. Half-day mediations for single-plaintiff cases, including up to four hours of mediation time, are available upon request.
Mediation fees are invoiced when the mediation is scheduled. Payment is required to confirm and maintain the mediation date and must be received before the mediation session. Fees are fully refundable if the mediation is canceled at least three weeks before the scheduled date.
Approach
Mike approaches mediation with a focus on preparation, practical judgment, and moving cases toward resolution.
Experience
Mike draws on more than 25 years of employment litigation experience and has conducted hundreds of mediations involving wage and hour class actions, PAGA matters, and high-stakes single-plaintiff cases. He understands how these cases are valued, where risk lies, and how they are resolved. He uses that perspective to help parties reach practical outcomes.
Adaptive
Mike adapts his approach to the needs of the case and the parties. Some matters require a direct evaluation of risk; others benefit from a more facilitative approach. Mike is comfortable adjusting in real time to what will move the discussion forward.
Persistent
Mike stays engaged when negotiations become difficult or stall. He continues working with the parties to identify movement, test positions, and explore paths to resolution.
Respect
Mike works with all parties in a direct and respectful manner. He understands that even contentious cases benefit from a professional and measured approach, which helps maintain productive dialogue.
