Complex mediation involves matters featuring particularly vexing and sophisticated issues, challenging the parties and the mediator. Often associated with fundamental and ambiguous insurance coverage issues, such cases require deep experience in the underlying business and legal issues, together with the interpersonal skills necessary to manage and sequence consideration of the subject matter in a cohesive format leading to a negotiated resolution.
Complex mediation usually involves multiple parties, and brings into play the necessity for managing the parties and counsel skillfully in order to keep all positively engaged in a spirit of cooperation and progress toward resolution. Of particular importance in complex mediation matters is thorough review and preparation by the mediator, including reviewing and studying all relevant materials in advance, as well as discussing the issues in depth with counsel for each party prior to the complex mediation.