Mediators work on numbers and documents. When counsel can answer a question by turning to a tab instead of calling the office, the day goes better for everyone.
The core tabs
- Case summary: parties, claims, defenses and procedural posture on one or two pages.
- Damages summary: each category, the amount and the document that supports it.
- Chronology: the key dated events, each cited to its source.
- Key documents: contracts, correspondence and the handful of exhibits that matter most.
- Medical summary, in injury matters: providers, treatment and billed and paid amounts.
- Testimony excerpts: the deposition passages counsel expects to rely on, with page and line.
- Prior offers: the history of demands and offers, by date.
Paper and digital
Many attorneys want both: a tabbed paper binder and a bookmarked PDF that mirrors it. The two should match tab for tab so nobody has to translate.
Timing
Build the binder from material counsel already has, and leave time for review. Most of the work is gathering and indexing, which is exactly what can start weeks ahead.
Our exhibit list builder helps organize the key documents tab.
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This article is general information, not legal, tax or regulatory advice. Rules change; confirm current requirements with the responsible agency or a licensed professional.
