Mediation Process

Precision Thinking.
Practical Solutions.

Peg Carew Toledo brings her passion for problem solving, deep curiosity, and ability to quickly comprehend and synthesize complex facts and law to facilitate the resolution of high stakes litigation. Her approach is defined by meticulous preparation, active listening, and building trust with all parties and counsel. Peg’s curiosity is a key to maintaining the requisite neutrality because a curious mind remains non-judgmental and impartial.

Peg is both analytical and empathetic. She efficiently masters the technical aspects of the case while expertly navigating the human dynamics that often derail negotiations. She comprehends the science, grasps the legal nuances, and understands what really drives each party. She excels at offering practical perspectives and candid assessments based on her decades of litigation experience. In high conflict cases, Peg skillfully holds space for intense emotions and sensitive subject matters while simultaneously managing a productive mediation process.

Every Dispute has a Beginning, a Middle, and an End.

Process Initiation

The first step in the process is scheduling a mutually agreeable date for the virtual or in person mediation session. Once a date is reserved, Case Manager Nikki Safavi will send counsel a mediation package including the notice of mediation, the agreement to mediate, and briefing guidelines.

Before the Mediation Session

Mediation Statements:
For most mediations, it is helpful to have the parties provide statements that they will exchange with the other party or parties and also submit confidential statements to convey information that will not be shared with the other side.

Pre-mediation Conference Call:
Subsequent to receiving the statements, but prior the mediation, Peg will contact each party’s primary contact for a brief discussion of the case and that party’s perspective.

Mediation Location

Peg is available for mediation throughout California and nationwide. The mediation session can be held in the location preferred by the parties in the office of any participating counsel or other available offices. The session may also be conducted over Zoom or other virtual platforms.

The Session

Peg’s approach to mediation is tailored to each case’s unique needs. Peg works with counsel to determine the session structure that best serves the settlement objectives of each individual case. Typically, Peg does not open a mediation session with a substantive joint session unless the parties believe that a joint session is warranted.

Mediation Fees

Toledo Dispute Resolution charges a flat rate for full-day or half-day mediations. The flat fee includes the mediation session, review of mediation briefs, pre-mediation discussions with counsel, and reasonable follow-up. There may be additional charges for mediations involving more than two parties and mediations requiring travel outside of Northern California. Rate quotes are immediately available by emailing Nikki@toledodr.com.