Mediation Agreement

A draft Mediation Agreement will be circulated to the parties prior to the mediation.


The venue should be agreed upon and arranged and paid for by the parties. Kerry can arrange rooms on her floor in MLC Centre, costs on application.

Preliminary conference

Preliminary conferences are not always necessary but can be useful, particularly in multi-party proceedings.

Position papers and bundles of documents

Position papers and bundles of documents are required in litigated matters where the parties are legally represented. Parties should be aware that one hour of preparation time is allowed within my daily rate, half hour within my half-day rate. Large bundles of documents may increase the cost of the mediation. If the bundle is not voluminous, Kerry is happy to receive it by email.

Authority to Settle

As per the draft Mediation Agreement, ‘Each Party must be represented at the Mediation conference by a person or persons having or able during the course of the mediation to obtain authority to settle the Dispute.’

Payment terms

Payment should be made within 30 days of the issue of my tax invoice.