Resources for counsel & insurers

Practical guidance for attorneys, adjusters, and claims professionals scheduling mediation with Fallon Mediation.

For counsel Scheduling intake Nationwide virtual Fee guidance Check availability

Scheduling a mediation

To schedule a session, send an email to info@fallonmediation.com with the following information to expedite scheduling:

Case caption, docket number, and court (if pending)
Names and contact information for all counsel of record
Parties for conflict check
Dispute type and estimated complexity
Preferred date range for Zoom session
Forum state and jurisdiction (if pending litigation)
Location of parties and counsel
Whether the matter is court-ordered or voluntary

Nationwide virtual mediation

Counsel across the United States regularly select neutrals outside their home jurisdiction for complex commercial, insurance, and pre-trial matters. When parties agree to Seric Fallon as mediator, Fallon Mediation conducts structured virtual sessions with the same confidentiality, caucus structure, and pre-session brief review.

Virtual mediation is especially effective when:

Parties, carriers, and counsel are located in different states
Travel costs or schedules make travel impractical
Insurance or commercial disputes involve national carriers or multi-state operations
Pre-trial litigation requires a practitioner-level neutral with litigation experience

Important: Seric Fallon is admitted to the Florida Bar and D.C. Bar only. Nationwide availability is through virtual mediation when parties agree on the neutral, not bar admission or legal practice in other states. Court-ordered mediation requirements, ADR procedures, and contractual mediation clauses vary by state and forum, counsel should confirm that a privately selected virtual mediator satisfies applicable rules before scheduling.

Matters we mediate nationwide

Fallon Mediation is frequently selected for disputes that counsel refer to experienced neutrals regardless of location:

Commercial contract and partnership disputes
Insurance coverage, bad faith, and multi-carrier mediations
Pre-trial and mid-litigation civil cases
Professional liability and complex liability claims

Pre-mediation briefs

Thorough preparation is essential to productive sessions. Each party should submit a confidential mediation statement in advance. Effective briefs typically include:

Factual summary: Key events, disputed facts, and procedural posture.
Legal issues: Primary claims, defenses, and coverage positions where applicable.
Damages and exposure: Valuation analysis, expert opinions, and prior settlement discussions.
Settlement history: Prior demands, offers, and impasse points.
Authority: Confirmation that decision-makers will be present or immediately reachable.

For insurance matters, include relevant policy provisions, denial letters, and claims handling chronology. Seric reviews all submitted materials before the session and expects counsel to be prepared to engage substantively on the merits.

Session expectations

Mediation sessions typically open jointly, followed by private caucuses as needed. Seric maintains strict neutrality and confidentiality throughout. Parties should arrive with settlement authority or immediate access to someone with authority to bind their client within an agreed range.

For multi-party insurance mediations, carriers should send representatives with settlement authority. Claimant counsel should have discussed realistic parameters with their clients before the session.

Bar Admissions

Florida & District of Columbia

Experience

19+ years complex civil & commercial litigation

Affiliation

Partner, Zumpano Castro

Session format

Zoom, nationwide

Scheduling & Fees

Transparent fee guidance.

Fallon Mediation provides clear billing practices. Specific rates are confirmed at scheduling based on case complexity, number of parties, and session format.

Fee structure

Mediation fees are typically billed on an hourly basis and divided equally among the parties unless otherwise agreed in advance. Fees generally include:

Pre-session review of briefs and materials
Time spent in joint and caucus sessions
Communications with counsel before and after the session

Request a fee quote when you schedule; rates are confirmed based on case complexity and number of parties.

Billing & logistics

Invoices are issued upon conclusion of the mediation
Billing is directed to counsel of record unless otherwise arranged
Rescheduling requests should be made as early as practicable

For rate information: Include case details and preferred dates in your scheduling request. A fee quote and engagement terms will be provided before the session is confirmed.

FAQ for Counsel

Common questions from attorneys.

What should I include in a scheduling request?

Provide the case caption, docket number, names of all counsel, parties for conflict check, dispute type, and preferred dates. For insurance matters, note whether first-party, third-party, or coverage-only issues are involved.

Are pre-mediation briefs confidential?

Yes. Briefs and all communications in connection with mediation are treated as confidential. Materials submitted are reviewed solely for mediation preparation and are not shared with opposing counsel unless authorized.

Can mediation proceed while litigation is pending?

Yes. Most mediations occur while cases are actively pending. In Florida, courts frequently order mediation under Rule 1.700. A successful mediation resolves the case; an unsuccessful session preserves all litigation rights.

Can counsel in different states mediate together virtually?

Yes. When all parties agree on Seric Fallon as neutral, virtual mediation brings participants from any state into a single confidential session. This is common in commercial and insurance matters with geographically dispersed counsel, carriers, and clients.

Does court-ordered mediation in another state require a local mediator?

Requirements vary by court, forum, and order. Some jurisdictions permit parties to select a mutually agreed neutral regardless of location; others may require a roster mediator or in-state provider. Counsel should review the court order, local ADR rules, and any contractual mediation clause before scheduling a virtual session with an out-of-state neutral.

Does Seric Fallon mediate outside Florida and D.C.?

Yes. Virtual mediation is available nationwide when counsel agree to Seric Fallon as neutral. He is admitted to the Florida Bar and D.C. Bar only.

What happens if the session ends in impasse?

Parties retain all litigation rights. No statement or admission made during mediation is admissible in subsequent proceedings. Partial agreements reached during the session remain enforceable.