Pre-mediation submissions from counsel about the facts of the case, the legal issues involved, the nature of the parties, and the status of the legal proceedings are extremely helpful. All such submissions should clearly indicate whether or not their contents have been disclosed to the other side, or are to be kept confidential. Pre-mediation submissions need not be in Mr. Cohen’s hands more than a few days before the mediation, unless the Court has ordered otherwise.
Pre-Mediation submissions should be sent by either email, overnight
courier or facsimile