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Thoughts on how to settle disputes and resolve complex situations.


The fine print.


Mediation Fee Schedule

Full Day Mediations in Dallas

Our mediation fee covers all preparation time, individual meetings or calls in advance of the mediation, the mediation session itself, the use of our mediation facility, scheduling and administration of the mediation, a working lunch, and appropriate follow-up telephone calls with counsel, if necessary.  The fees payable by each party are as follows: 

Amount in Controversy Fee Per Day Per Side
Up to $1 million $3,750
$1,000,000 – $5,000,000 $4,500
$5,000,000 – $10,000,000 $5,250
More than $10,000,000 $6,000 or TBD
For these purposes a “side” is a party or group of parties represented by the same law firm or firms. Parties with different law firms are considered different sides. In cases with four or more sides, we are happy to discuss a reduction from our standard per party rate.
The amount in controversy is the aggregate amount of all claims for affirmative relief by claim or counterclaim, which may be adjusted if subsequent settlement demands have reduced the amount genuinely in dispute.
When there are substantial non-monetary issues (such as requests for injunctive or declaratory relief) or other special circumstances, we will set the mediation fee after a discussion with counsel.
Mediations Outside Dallas 

For the time being, we are only mediating at our offices in Dallas or on Zoom.  In the future we will return to our previous travel policy, which was: Mediations beyond an early morning drive from Dallas require an overnight stay the night before the mediation.  Our practice is to travel during the morning the day before an out-of-town mediation so we can meet in person with counsel in separate sessions the afternoon before the next day’s mediation.  Accordingly, our fee for out of town mediations is our applicable daily rate for two days plus estimated travel and lodging expenses.  If a third day is required for travel back to Dallas, that day is absorbed at no extra cost to the parties.

Half Day Mediations

We actively discourage half day mediations, as they are often ineffective in the types of cases we mediate. 

The Fine Print

Full payment of the mediation fee should be received at least 3 business days prior to the mediation date.  All fees will be waived if the mediation is cancelled at least 7 days prior to the scheduled date.  If one side cancels the mediation within 7 calendar days of the scheduled mediation date, we will charge that party for the mediation fee allocable to one side.  If more than one side cancels during this time frame, the cancellation charge will be allocated pro rata among the sides.  All cancellation fees will be refunded or waived if another mediation is scheduled for the reserved date.

Arbitration Fee Schedule

Arbitration Rates

John’s arbitration rate is $675 per hour for hearing, study, and travel time, regardless of the number of parties.  Unless agreed otherwise this fee will be divided equally among the sides, and includes the use of our Deep Ellum ADR Center, including breakout rooms for up to 6 sides.  An advance deposit based on the anticipated time required for the hearing and all pre-hearing and post-hearing activities is required.

The Fine Print

Unless otherwise agreed, any retainer in excess of fees already earned will be returned if a matter is cancelled more than seven days prior to the hearing date.  If a hearing scheduled for 3 days or less is cancelled or postponed within 7 days of its start date, we will charge a cancellation fee of $3,375 per cancelled day.  Other arrangements will be necessary in those cases where more than three days are reserved for the hearing.