SvsG Plaintiff's Lawyer To-Do List

This is a list of things (re Staddon vs. Griever) which Nick is waiting for his lawyer to take care of.

• Nothing significant at present; phone call scheduled for 2005-11-02 2:00 pm to plan for mediation and discuss questions asked earlier (email and printout):
  • Why were we able to compel the Defendants to answer questions earlier but no longer have that option? (This being the case, I believe we made a significant tactical error in the questions and statements we chose for the Defendants to respond to, in that they are for the most part very general and address very few specific points, leading to a number of problems which I have discussed elsewhere.)
  • Was I informed, before we sent in our first (and apparently only) round of questions and statements, that it would be the only chance to do so?
  • If you do not have a copy of the August 25 court order, how did you become aware that mediation had been ordered?
  • Why was mediation ordered? Should I have been aware that this was a possibility? My understanding was that we would have to request it before it could be ordered, and as far as I know, we did not request it.
  • Is mediation likely to take longer than one day? (I have a number of compelling reasons to avoid travelling to Athens more than is absolutely necessary. I believe written negotiation could, over time and with minimal lawyerly intervention, distill the dispute down to a set of issues which could be easily resolved in a single sitting, while the current morass may take some time for a mediator simply to understand, let alone to begin untangling.) (10/29 update: according to the brief Information About Mediation sheet I received, "Mediation is usually just a one-time conference. Most last no more than two hours.", so it would be reasonable to expect the process to be quick, and it would also be reasonable to propose an alternative if the situation looks too complicated to resolve in a single session.)
  • Will there be a written record of the mediation? (10/29 update: the Information About Mediation sheet says "No recording devices are permitted during the session." This is a problem. Possible resolution: agree to make a recording, but destroy it once a satisfactory agreement has been reached. As long as the negotiation is still up in the air, I will want a record of what has been said thus far.

Past Issues

1. Postponement of 11/10 mediation date due to need for questions to be answered first (10/29 update: current plan is to keep written negotiation as a backup plan, in the event that in-person negotiation starts dragging on with no resolution in sight)
   • Also, further discussions of proposed electronic negotiation are waiting on this, as I do not intend to let this go to face-to-face discussions of any kind if it can possibly be avoided (unless Grievers are willing to travel here for every other date, which seems most unlikely)
2. Copy of 8/29 court order (as mentioned in 9/19 court order)