Lee Arellano





1. Please list the style, case number and court in which the dispute is pending.

2. Please state the total number of persons you intend to bring to the mediation, including yourself and state the total number of rooms that you believe will be necessary to conduct this mediation based on the total number of represented parties.

3. Please provide the name(s) of all opposing counsel, the party they represent, and the pro se litigants, with as much contact information as you have of such persons.

4. State the nature of the Plaintiff’s claims and the Defendant’s defenses and counterclaims:

5. What relief does the party you represent seek?

6. What are the primary disputed issues of law or fact in this case, from your perspective?

7. What is the status of discovery? (1) little or none; (2) some discovery done but substantially incomplete; (3) substantially complete or incomplete.

8. Do you have sufficient information to form a realistic settlement position? If not, what else is needed?

9. What are the last offers of the parties, if any?