Let's face it, some attorneys "prepare for a mediation" and some"PREPARE"! Good litigators always look at a mediation as a chance to strut their stuff, and maybe even settle, or get closer towards settlement. Of course you want to hold a little something back too.
Part of the preparation process is to "get a handle " on all existing liens; including funding liens. That way at the mediation, during potential $ discussions you are keenly aware what number you need to get, to put "x dollars" in the client's pocket.
All it takes is an email to me 3 or 4 days before the mediation requesting "a payoff amount good for 30 days after the date of the mediation".
I can usually turn around a request in under an hour.
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