Fees, Policies, and Scheduling

Fees

As of December 1, 2026, my hourly rate is $725. This rate applies to all of my time on a matter, including preparation, review of mediation statements and other materials, pre-session conferences, mediation sessions, and follow-up after a session, such as continued settlement discussions and additional sessions.

For cases involving more than two parties, group negotiations, class actions, or other complexities, or for very simple cases that need minimal preparation, please contact me to discuss the expected scope and any alternative fee scales.

Deposit and cancellation policy

To hold a mediation date, I require a deposit equal to at least 13 hours at my hourly rate ($9,425). For cases with more than two parties or unusual complexity, I may require a larger deposit. The deposit is applied against fees and costs as they are incurred. After the matter concludes, I will issue a final invoice, and the parties will either receive a refund of any unused portion or be billed for any balance due.

In the event of cancellation the deposit is fully refundable, less fees and costs already incurred, until two business days before the scheduled mediation session. If the session is cancelled or postponed within two business days of the scheduled date, 50% of the deposit is nonrefundable, in addition to any fees and costs already incurred. The cancelling party is responsible for any claim for reimbursement from the non-cancelling party.

Travel expenses and costs

I bill for reasonable expenses (mileage reimbursement for driving, airfare when applicable, hotels, parking and tolls) but typically not for travel time.

Facility expenses and costs

I can host a mediation of up to three parties at my office in Boulder.  There is no charge for this service.  Parties are responsible for the cost of any meals, which we can order and have delivered to the office.  The parties are responsible for any expenses and costs related to mediations at other locations.

Allocation of responsibility for fees and costs

Unless otherwise agreed, the parties shall be assumed to be dividing any fees and costs equally.  A represented party’s lawyers shall be responsible for the payment of fees and costs that are not promptly paid by their client.

Mandatory Pre-Session Conferences

In the weeks leading up to the mediation session, I hold separate virtual conferences with counsel for each side. Parties are welcome to attend. These conferences let me prepare and work with counsel on an agenda and process that give the case the best chance of resolving. They also let me identify and request information that may help, assist counsel and the parties in preparing, and make the session itself more efficient.

Mediation Statements

As a general matter, please submit confidential mediation statements at least one week before the mediation session. They should be on counsel letterhead and marked “Confidential.” However, we often determine the timing and preferable format and content of confidential mediation statements at the pre-session conferences. I also encourage counsel to consider preparing mediation briefs to exchange with the opposing party.   

Scheduling Mediation Sessions

Please contact me directly at ashoemaker@sgslitigation.com (303-530-3452) to schedule a mediation.