Fee Schedule and Cancellation Policy

Mediation Fees and Cancellations

As of January 1, 2025, Mike charges a flat rate for a full day of mediation of $8,000 for individual cases and $10,000 for class, collective, representative (PAGA), and other multi-plaintiff actions. This rate includes all preparation, including review of mediation briefs, a pre-mediation conference call, any necessary research or pre-mediation follow up, and any travel time and expenses. The flat rate also includes reasonable post-mediation follow up that may be necessary to effectuate a settlement. The mediation fee does not include any additional charges for mediation space if the parties desire an in-person mediation and one of the parties cannot host the mediation.  

Mike will also conduct half-day mediations for $6,000 for individual cases, which consists of four hours of mediation time at a flat rate. Should a half-day mediation continue beyond four hours, Mike charges an hourly rate. The half-day flat rate also includes all preparation, including review of mediation briefs, a pre-mediation conference call, and any necessary research or pre-mediation follow up. The half-day flat rate also includes reasonable post-mediation follow up that may be necessary to effectuate a settlement. 

Mike is also available to conduct early evaluation conferences for PAGA cases pursuant to the 2024 amendments to PAGA (Cal. Labor Code § 2699.3(f)). Mike charges $6,000 for a half-day conference or $10,000 for a full-day conference. As with the mediation rates, these rates include all preparation time, including review of mediation briefs, a pre-mediation conference call, and any necessary research or other pre-conference work. The half-day flat rate also includes any reasonable post-conference follow up that may be necessary to effectuate an agreement or obtain court approval.

Counsel, not the parties, contract for Mike's services and are responsible for paying all fees. All counsel are responsible, jointly and severally, for Mike's fees. Unless otherwise agreed, Mike will assume that the payment of his fees will be divided equally between/among the parties. 

Fees are due in full immediately upon Mike confirming the date and issuing an invoice. Fees will be refunded if the parties cancel in writing 21 days or more in advance of the scheduled date. If the mediation or conference is canceled or postponed 20 days or less before the scheduled date, the party requesting the cancellation or postponement is responsible for the entire fee (not just the canceling party’s share of the deposit) unless Mike is able to schedule another matter for that date.