Transcript

Pick a winner · Coopers' Code

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Howdy and welcome to the show. Cooper's code examines a legal
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issue and hits the highlights so we all achieve the best results
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for our clients. I'm Miles Cooper, and with
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today's guest, Kimberly Wong, Head of Litigation.
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At Cooper's, we will be discussing how to select the
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right meteor for a case and why that selection is so important.
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Before we get into today's topic, a few words about
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Welcome to the show. Well, thank you for having me.
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So today we're going to be talking a little bit about how
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we go about selecting mediators. And in that regard, as far as
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you were beliefs about mediation, do you think that
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selecting the right mediator is important?
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Of course we always try to prepare every case as if it's
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going for trial, but reality is, is that most cases settle and so
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mediation tends to be. Often the first opportunity to
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really talk about potential resolution of the case.
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So having a good solid mediator is going to set you up for
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success in that regard. Are there certain things as far
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as past experience that you initially consider when trying
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to make decisions about a mediator?
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Of course, there are a lot of different mediator backgrounds.
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Some are former plaintiff lawyers, some are former defense
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lawyers, and then we also have retired judges.
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And each brings their own unique experience and perspective that
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could benefit your mediation. So I'm going to speak in broad
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generalities. And I'm saying that because some
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of our listeners are going to be former defense lawyers, former
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plaintiffs lawyers and former judges.
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And I don't mean to offend any one of them by gripping them
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into this collective stereotype. But in your experience, I think
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we should break them down when you deal with a past defense
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lawyer, where the pros and cons in terms of a past defense
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lawyer and their background as what they bring to the table for
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a mediator. Actually, some of my favorite
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mediators are former defense lawyers.
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They get to see things that we don't get to see and how the
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sausage is made on the other side.
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And so they know what the pressure points are for the
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defense lawyers as well as the adjusters.
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There's so many things I don't know about how to talk to the
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insurance adjusters, what information they need.
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And so they provide that perspective with the plaintiff's
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lawyers us as to what we need to be able to provide them to be
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more persuasive to get to the reasonable settlement value.
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They also may have more St. credibility with the defense
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lawyers and the adjusters because they know that they did
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the same thing that they did and couldn't appreciate their
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background and how they're looking at the case.
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So I think those are the two biggest pros for using a defense
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lawyer because the other side will really respect and trust
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them. Never had experiences with
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defense lawyer mediators doing things like writing white paper
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or an opinion or something to go back to the adjuster to work
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with a committee to get the number put on the table that's
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necessary to resolve the case. Surprisingly, I haven't.
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I asked that only because also a trend to lean towards defense
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lawyers as my favorite mediators.
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There are reasons for plaintiff's lawyers or judges,
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and we'll talk about that. But I've had experiences like
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that where the defense lawyer on the other side agrees with the
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mediator but is having some trouble, and the mediator has
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volunteered to make a presentation to the committee or
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to write a paper to help them understand the exposure.
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That sounds like a great idea, yeah.
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And I think you're absolutely right, because that idea comes
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from the defense experience of having to do reporting and
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having to help our words paper the file to properly put the
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right amount of money on the table.
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Also, and I'm adding on to some of your thoughts about defense
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lawyers, I've had more than one defense lawyer mediator come
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into the room and tell me how much they hate insurance
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companies. And I think no one gets the
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experience of being mistreated by an insurance company quite
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the same way as defense firms who work for them and then have
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their bills audited. Have you had similar comments
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from defense lawyer meteors? I can't recall, but I'm not
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surprised. I sometimes find that they have.
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I'm not a vested interest, but the notion that they might be
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biased towards the defense is actually the opposite.
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Let's switch into to plaintiffs lawyers as meteors.
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What of your experiences, pros, cons in that regard then?
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Well, plaintiffs lawyers have sat in our shoes and so they
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know what we're facing in communicating with our clients
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and sometimes as best as we do to.
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Explain to our clients what to expect with the outlook on their
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case, what a reasonable settlement range is, How did the
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liability might look in front of a jury?
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How would their damages look? They thought the client
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sometimes needs to hear from a neutral person to basically back
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you up. And so I think that's probably
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one of the biggest pros of use, a plaintiff meat eater if you
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find yourself in that situation with the client who needs to
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hear that also sometimes. Former plaintiff lawyers, They
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really know how to communicate with your clients and get
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through to them in ways that maybe other people don't because
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they have that experience That makes a lot of sense.
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Are there any cons, downsides that you worry about in
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selecting A plaintiff's lawyer, potentially as a mediator?
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Sometimes the insurance adjuster or the defense lawyer may think
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maybe this mediator is slightly more biased towards the
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plaintiff side just because of their background.
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I think that's probably the biggest one I might come across.
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I have, and it is very rare, but on occasion I have seen a
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situation where a plaintiff's lawyer I feel, might be leaning
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a little bit defense ish in order to make sure that they
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don't lose credibility because of their plaintiff's background.
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Have you ever had an experience like that?
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Not that I overtly saw. Now leaning in to judges your
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views on pros and cons for selecting a judge as a mediator.
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Judges have all kinds of backgrounds.
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Some have served as settlement conference officers, which can
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be invaluable because they spend every day mediating trying to
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resolve cases. And then there are other judges
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who have extensive trial experience in overseeing trials,
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so they really know what the outcomes are of these cases if
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they don't settle at mediation. And they can communicate it to
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either side, whichever is more useful to communicate to
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depending on the situation. So those are the insights that a
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judge would offer that are unique to them.
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Do you have certain types of cases that you lean more toward
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a judge for than others? I don't know if you've ran into
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the situation, but I've had some insurance adjusters or defense
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counsel will say we will only mediate with a retired judge.
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In general or for this case, and in those situations, I don't
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have a choice but to pick a retired judge.
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I have had situations like that. I find that more frequently
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comes up usually in an individual case, And it may be
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an individual case where there are liability issues or some
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piece where they feel the imprimatur of a judge saying,
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well, you know, if this case were before me, I might rule on
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this particular significant evidentiary issue this way or
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that way. I would also consider using a
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retired judge for complex cases or cases involving a lot of
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parties, a variety of legal issues, because there are
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certain mediators I can think of who are retired judges and they
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just have an excellent reputation on both sides for
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their history in resolving cases at settlement conferences.
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And so they bring that to the mediation realm.
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I agree with that. I think that there are a lot of
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great judges who are mediators. There are a few experiences I've
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had, and it's very few where. And I use the analogy of how
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most generals don't make great presidents.
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They've relied too much on the power of the robe as opposed to
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the power of persuasion. Those sometimes are not as
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effective mediators, and I also find that those are the same
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ones who don't do all the follow up the same way that I like to
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see from a a judge. Right.
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I think just because they were a judge doesn't mean they're gonna
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be a good mediator. You have to look at what their
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experience was as a lawyer, but also as a judge.
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Anything else that we should be considering in terms of past
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experience? In terms of talking through how
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to how to select the right mediator for a case?
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For everything that we do in practice, trust your gut.
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So if something feels a little lost, then consider someone else
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that makes sense switching into personal style.
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Have you had experiences with different mediators having
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different styles? Absolutely.
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What types of styles have you seen, and what types of styles
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do you consider when trying to pick the right mediator for a
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case? So one would be their
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methodology. I pretty much would only select
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a mediator who I'd say is committed to doing whatever they
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can to bridge the gap between the parties.
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I like to use mediators who will either haul you before the
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mediation to see what's going on or welcome that call.
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I also love the mediators who will read the whole brief and
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the exhibits and be very familiar with what's going on.
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And the ones who are committed to continuing on after mediation
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is over to do whatever they can to help the mediator who
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mediates for the case as opposed to the mediator who mediates for
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the day. Correct.
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As we talk about style, I also think style can sometimes
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include personality. What personality considerations
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do you have when selecting A mediator for a case?
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I'm not. That's like a judge temperament
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and their personality. Unfortunately, I've had
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experiences where the mediator doesn't realize how they're
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coming off to our clients. A little aggressive,
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condescending, not listening. And so if I have one of those
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experiences, I would not use them.
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You raise a good point. There are lots of people who
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seem to be getting into mediation, and some of them are
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great, but not all of them bring the same set of skills.
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And given that there are so many mediators out there, it gives us
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an opportunity to really pick the right one for a case.
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Sometimes you do have to take into consideration who your
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client is and how they might respond to that neutral.
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And likewise, you know, if I had an opportunity to pick amongst a
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few mediators and one of them I know had a similar background to
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my client, and the client might relate to that person or want to
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hear from them, that mediator may get an edge over the others.
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Also, within the category of style, style also includes
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mediation method. Are there different mediation
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methods that you've seen, some of which are better, some of
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which are worse, some of which are right for one case but not
11:55
another? I'm curious to hear your
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experience on joint sessions, because when I started out in
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practice they weren't very common, but they happened on
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occasion and now I think it seems that the common consensus
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is no one likes them. They tend not to be effective.
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It's interesting because when I first practiced, it seemed like
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there was always a big to do about a joint session, have a
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presentation, get up, bring everyone in, show the show,
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demonstrate to the other side why you're going to be able to
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prevail on the case. And over time, it seemed like
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everyone moved away from that and the collective learning.
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And I don't know if you've had this experience in in kind of
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those big pomp and circumstance joint sessions is there's a big
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joint session and then the media has to spend the next hour and a
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half calming down the other side who just feels like they got
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dumped on. Yes, I think the joint sessions
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tend to be polarizing, which is why people aren't doing them
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anymore, unless both sides actually ask for it.
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I think you're right. I've seen effective ways of
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approaching a joint session, which is letting the other side
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know. Look, we'd like to do a joint
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session. We'd like to show you our view
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of the case. We don't want to polarize the
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discussion. We don't expect you to rebut any
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of the things we're doing. We don't want to embarrass you
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in front of your client, but we want to show you why we think
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we're going to be able to prevail in the case.
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Would you be open to that? And we would encourage you to
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ask us questions during that joint session.
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I've seen those translate into taking an entire morning where
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it's been a very robust back and forth and the case might not
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resolve that day, but it certainly helps the other side
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see things as opposed to the ambush style joint session.
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And I think so many of the joint sessions were seen as ambush
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style media will bring people in, you know, Do you plaintiff's
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lawyer have anything to say? And the plans lawyer would get
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up and for 10 minutes would dump on the other side.
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The other side would feel they need to get up for 10 minutes,
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dump on the plaintiff side and then things would go to hell.
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You know, it's all about the messaging on the joint session,
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and both sides will have to see the benefit of it before you do
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it. Otherwise it's just gonna be
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polarizing. But you know another thing that
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you could do instead of a joint session sometimes if you've had
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the benefit of a focus group. I share parts of what I learned
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from the focus group because. That is the most valuable
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information is what would a jury say if we took this to trial and
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they don't have that insights that you've gathered from a
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focus group agree, and I like sharing that when we have that
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information, I've found most of the time we share that room
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mediator in single session as opposed to joint.
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Yes, and I was saying that as an alternative to a joint session
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where you can communicate a similar message of this is how
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the case will look. And then I would also say.
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It's not quite a joint session, but something that I'd be open
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to is if the adjuster says, hey, I would like to meet your client
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just to see a face because sometimes there's no video
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deposition of the plaintiff or they haven't for some reason
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taken the deposition yet, which is unusual at that stage.
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I would be open to that if that's something that they felt
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that they needed, just especially if our client makes a
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good presentation. It's not a conversation, it's
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just a greeting of hi, nice to meet you, I agree with you.
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I think that that's for me an important tool that we will
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often times offer to the mediator.
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Not that we want to have a big drawn out joint session, but I'm
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sure this is your experience. These days everyone starts in
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separate session, but at some point if the mediator feels it
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is useful for us to bring in exhibit 1, the client that we
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can have that joint session. And I usually will have the
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mediator guide the conversation. You know, have the mediator
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throw softballs at the client and we'll talk about this in
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another podcast. This goes a little bit into the
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client prep though, in terms of making sure the client is aware
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that this might happen so that they're not caught off guard.
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Other style things that come up are how the mediator approaches
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the process in terms of learning about the case and learning
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about positions. I like a mediator that's
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confident but flexible. I tend to lean a little bit on
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the mediator as to. How to make the next move?
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You know whether are we going to continue to exchange numbers?
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Should we switch to brackets? Are we at the point where you'll
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be worthy to do a meat eaters proposal or are we done for the
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day? Because the meat eaters the only
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one who has the pulse from both rooms.
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So I want someone who is confident to know what they're
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feeling from both rooms and also have flexibility.
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To adjust depending on what's going on and make
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recommendations, of course. That style, that being willing
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to provide some guidance and be flexible, I think is critical.
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It makes the difference between somebody who's going to be able
16:51
to close the gap that day or later versus one who just, you
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know, throws up their hands and says well, can't get it done.
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Since the pandemic we've seen how almost everything has rolled
17:03
into a video or zoom world. Depositions and mediations
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specifically, Have you had many in person mediations since this
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whole COVID mess started? Zero.
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How about you? We've had two.
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It seems that people like not having to travel and I've found
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that we've been very successful in resolving cases and doing the
17:29
one video. I found that the two that we
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chose to do for very specific reasons, it was very beneficial
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to do those in person. So on the location side, do you
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have any consideration that you raise with, say, the other side
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in terms of whether we should do something in person?
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I personally have not come across a case that I felt would
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benefit from an in person mediation since the pandemic
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began, but I am sensitive to that.
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There are some cases where it would absolutely make sense,
18:00
agreed. And in our case, the one that
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I'm thinking of primarily, it was a fatality case and we had a
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mediator who had just the right warmth for working with people
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where it was an awful, awful situation.
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And so I think that it was the mediator's suggestion request
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that we meet in person. And for that, I think that was
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the right choice, giving this topic a little bit short shrift
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because I would say 95% of cases are now remote.
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If we're going to do a physical mediation, are there certain
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things that you would look for? But knowing their layout in the
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office space, where people being put, what kind of privacy is
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there? Some places have glass walls.
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You want to prepare the client for that.
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There is one mediation facility that for years is beautiful.
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They had all glass offices with no blinds to bring down.
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And I would never have a client at one of those mediation
19:01
facilities if the client didn't have a poker face.
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I feel like I can't pick that mediation facility because with
19:07
this particular client, I'm worried about people walking
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down the hall. Also, how thin are the walls?
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Good mediation facilities will put you on the far side of the
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building from the other side, yeah, pivoting into talking
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about the selection method itself.
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Are there ways that you work with the other side to try to
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get to that point of the delicate dance of selecting the
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right mediator? What methods do you use?
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They usually ask the other side to propose 5 mediators that
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their client and they would feel comfortable with.
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Inevitably, I get the same request in a lot of cases.
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In that Venn diagram of overlap, do you find that you see names
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that you and the other side can routinely agree on?
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Sometimes yes. And then there's sometimes when
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I initiate the request for five names and they don't give me any
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names and they insist only on my 5 names.
20:03
Interesting. When you are doing that, what
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considerations do you have when you put those names forward?
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I like to use known commodities because they're the tried and
20:15
true. I know what I'm getting when it
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comes to their experience, their methodology, their style, their
20:23
personality, their success rate. At the same time, I will also be
20:29
open to new names that they might propose.
20:32
Research and vet them. It's not a hard no, but some
20:36
names are familiar that you've heard from colleagues that are
20:40
good quality medias that you just personally haven't
20:42
experienced yet. I think of some names recently
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where I've had people say, my gosh, you haven't mediated with
20:49
so and so yet you've got to get her on your list.
20:52
She is fantastic. And you're right about the known
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commodity piece, and I think the known for me, the known
20:58
commodity piece is you're talking about a lot of time and
21:02
a lot of money and it's hard to break free of that concern that
21:07
you're going to work with somebody who you haven't worked
21:09
with before. At the same time, I've found
21:13
that when I've broken free, I've discovered some my new
21:16
favorites. Yeah, we use the same mediator
21:19
too many times and you get a reputation for that.
21:22
Maybe I'd see that there's otential bias there, so that's
21:26
another consideration. So it's nice to have a larger
21:29
group of mediators to select from, as we're talking about
21:33
selecting meteors. Have you had any experiences
21:35
where somebody who normally might not have been picked as a
21:37
mediator is now on the list? Because we're all remote now.
21:43
Yes. And that's one of the greatest
21:46
benefits of remote mediations is you don't need to pick a local
21:51
mediator if we're not going to be there in person.
21:54
So I've actually used a Southern California-based mediator.
21:59
Last year for mediation and we actually only stumbled upon him
22:04
because we were running out of options from local mediators
22:09
that we knew. And frankly, I have never used a
22:12
Southern California mediator before.
22:14
And you know what, the other side hadn't either.
22:16
And we were going based off of availability.
22:21
Nowadays, mediators are booking many months in advance, and so
22:25
defense counsel had said. I recently went to this
22:29
mediation where the plaintiff had proposed this media and said
22:33
they were excellent. I've done some vetting on my end
22:37
and I would be agreeable to that mediator.
22:40
And then I went ahead and called a bunch of Southern California
22:45
consumer attorneys and asked if they had any Intel on this
22:49
person. And they were raving about this
22:52
mediator who was actually a former defense lawyer.
22:55
And I thought, you know, this is probably a good case to try it
22:59
out. It wasn't a complicated
23:01
liability case. So it was more straightforward.
23:04
So I didn't feel like I was taking as much of A risk.
23:07
And we got a great result. And I asked the mediator about,
23:12
you know, how often do you mediate with people in Northern
23:15
California? Is this a rarity?
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And he said, no, I do mediations all across the state.
23:21
I even do some outside of the state now that there's so many.
23:25
Remote mediations. I actually chatted with him
23:28
before I agreed to the mediation to get some of his background.
23:33
And I just got a good sense from him cuz I asked, do you have a
23:38
pulse on what's going on in these different counties you
23:41
know that you're not practicing in?
23:43
And he did. And that's where I could see
23:46
that coming up as a concern. Sometimes it has been a
23:50
challenge to find a mediator in say the Central Valley.
23:53
There just aren't as many from that region as there are from
23:56
Northern Southern California. And when pre pandemic, when we
24:00
have proposed people from the Bay Area, you'll get pushback
24:04
like so and so is going to have two high numbers.
24:07
They don't understand the geography, they don't understand
24:10
the area. It sounds like this person had
24:13
done his homework. Yes.
24:15
And rightfully I needed to as well.
24:17
I kind of felt like I was doing a little deposition and I asked
24:20
him, so how do you know about what?
24:23
The San Francisco jury would do versus a jury in Fresno.
24:27
And he gave me some answers about he has mediations all
24:31
across the state, so he with cases that are venue everywhere.
24:35
He also has a good network of mediators that he would reach
24:39
out to, to bounce ideas off of. And he had decades of experience
24:46
as a defense trial lawyer himself that he could build
24:48
upon. And I don't want to ignore the
24:51
nugget that you dropped in there in selecting the mediator.
24:56
You called the mediator before you decided on the mediator to
24:59
have a conversation now. Well, it makes sense that anyone
25:03
can do that. I can say, well, I've done a lot
25:07
of vetting of calling other lawyers, looking at people's
25:10
backgrounds. I can't think of a time where I
25:12
actually was creative enough to say, you know, I want to give
25:15
this person a shot, but I want to have a conversation first.
25:17
Have you done that before? No, this was a unique situation
25:21
because. I wanted to feel comfortable
25:23
using a mediator that neither side had used before, and it was
25:28
great because I loved his personality and temperament.
25:32
I asked him about his style, like, do you do joint sessions?
25:35
Like what is your approach? Do you are you involved after
25:39
you know? That was really important to me
25:41
in selecting a good mediator. And I also want to point out I
25:45
don't know how other people vet mediators with colleagues, but I
25:50
don't really just get. Oh yeah, they're great.
25:53
They should be on your list. No, I want to know details.
25:55
Give me an example. Like, what made them stand out?
25:59
They went the extra mile because they kept calling even when I
26:03
never thought we would get a result.
26:06
Like they followed up three months later when some meetings
26:08
they give up after a couple days.
26:10
So knowing the specifics really tells a lot.
26:14
Very helpful. The other thing that is a
26:17
concern for me is making sure that the list that one provides
26:23
includes some diversity, both in terms of ethnic background but
26:29
also sex. Because I find often times when
26:32
I ask for a list of five from the other side, I will get 5 old
26:36
white dudes. And with that bias towards you
26:39
working with people that you've worked with before, it furthers
26:43
the bias towards the same privileged group always in that
26:48
same role. When you're pulling your list
26:51
together, do you do anything purposeful as far as that's
26:53
concerned? I actually do the same thing,
26:56
and you're right. Unfortunately, though, when I do
26:59
propose that list, usually the female mediators or the diverse
27:05
mediators are rejected solely because the other side doesn't
27:10
have experience with them. And so it's about giving them
27:14
the opportunity because these are experienced mediators and so
27:18
I just keep. Offering because sometimes the
27:22
other side agrees. One of the tactics we've used as
27:26
far as that's concerned is have our five list female.
27:29
Then you don't have the one male problem, meaning that they pick
27:32
the one male. On the list makes sense as you
27:36
are getting down to the brass tacks of making a selection and
27:40
going forward with a mediator. Have you ever had an experience
27:43
where something about going down the track with that particular
27:46
mediator tells you that it's not going to work?
27:49
Honestly, I haven't, but I always believe in trusting your
27:53
gut. So if something feels off then
27:56
it's probably a good time to look at other options and very
28:01
rare for me, but I can think of 1 occasion we're in the
28:05
premediation phone call. The person was frustrated that
28:10
they had to have a premediation phone call and you could just
28:13
pick up on the energy in the communication.
28:17
And against my better judgment, I went forward with that
28:20
mediation. It was in when I hadn't worked
28:22
with before and not surprisingly, it didn't go
28:25
anywhere significant and the mediator didn't have much in the
28:28
way to follow up, which was different than what the person's
28:30
profile, the reputation that that person had.
28:33
But if I had gone with my gut instinct in that first phone
28:36
call of no, not right, I would have saved a lot of time and a
28:40
lot of effort and the effort of having to convince the other
28:43
side that we should do a second session, but not with the same
28:45
person. You know, some heartache on the
28:47
clients part too. And yeah, thank you for being
28:51
willing to come and talk about this today.
28:53
Anytime and thank you for listening today.
28:56
Please e-mail us at podcast at Cooperstoutlaw with questions,
28:59
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29:02
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