Use cases
Documents in mediation: persuasion, not admissibility
Mediation removes the two constraints that shape every other setting on this list. No rules of evidence apply, so nothing has to be admissible or authenticated. And the person you are trying to move is not a neutral decision-maker but the other side, or the adjuster behind them, who has spent months believing their own version of the file.
What replaces those constraints is an economics problem. You have a day, two rooms and a mediator who will carry roughly three ideas between them. A document only earns its place if it changes somebody's estimate of what happens at trial. Twelve carefully chosen pages beat a binder, every time.
Assembling a set that moves a number
Start from the decision you want the other side to make and work backward to the two or three facts that make it obvious. Then find the single page that proves each one. This is a different selection than the trial set: an unhelpful document you would have to disclose at trial has no place here, and a document that would be excluded but is plainly true belongs in the room.
Build it in Exhibit Room as its own trial, named for the mediation, so it never gets confused with the litigation set. Number simply, 1 through 10, because nobody is making a record. Then annotate harder than you would in court: a callout naming who wrote the email, an arrow to the date, a highlight on the sentence that concedes the point. You are building an argument, not a record.
Workflow in Exhibit Room
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Create a separate mediation set
A trial named "Okafor mediation, 3 Feb" keeps it distinct from the exhibit set you will use if the case does not settle.
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Pick ten pages, not a hundred
Import the PDFs and cut anything that does not change somebody's valuation. If you cannot say what a document changes, it goes.
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Annotate for a lay reader
Callouts and arrows do the work here. The adjuster is reading a document they have never seen while somebody talks over it.
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Cover what should not be seen
Use the visual redaction overlay for figures or identifiers that do not belong on a screen in a room you do not control, remembering it hides them on screen only.
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Order the set as a sequence of concessions
Arrange the exhibits so each one is harder to answer than the last. Then you can walk it in order with arrow keys and no shuffling.
Joint session and caucus are different rooms
In joint session you are performing for the other side directly, so a laptop on the table turned around, or a screen if the mediator's office has one, is enough. Fullscreen matters here for a specific reason: nobody should be reading your folder names or the title of the next document while you are on this one.
In caucus the mediator is your audience and the work is different. You are equipping them to argue your case in the other room, which usually means letting them photograph or take a copy of the two pages that matter. Decide in advance which pages you are willing to leave behind, and remember that anything you show can be described next door even if you keep the paper.
Mediation questions
Do exhibits in mediation need to be admissible?
No. The rules of evidence do not apply. Choose documents for persuasiveness and for how clearly they read to someone unfamiliar with the file.
Is it worth annotating if there is no jury?
More so, not less. In caucus your documents are often read quickly by a mediator who is trying to summarize them accurately to the other room.
Can I hide a figure on a page before showing it?
You can cover it with the overlay for on-screen display, but the number stays inside the PDF. Never treat that as a substitute for a properly redacted file.
Should the mediation set become the trial set?
Treat them as different projects. The mediation set is short and argumentative; the trial set is complete, numbered to the court's convention and built for authentication. The same split applies to arbitration sets, where the tribunal's directions control the numbering.
Put a ten-page settlement set together
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