Mr. Hughes discusses the dispute, parties, claims, and scheduling with counsel. Before the session, each party provides the information reasonably necessary for him to understand the issues.

Useful materials may include:

• Construction contracts and related agreements
• Change orders and requests for additional work
• Payment applications, invoices, and account records
• Project schedules and delay analyses
• Correspondence and notices
• Photographs, plans, and inspection reports
• Repair estimates and completion proposals
• Expert reports, when applicable

Mr. Hughes may bring the parties and their counsel together to identify the disputed issues and hear each side’s perspective. This is a structured discussion, not a trial or evidentiary hearing.

Mr. Hughes meets privately with each side to discuss the dispute, underlying interests, litigation risks, and realistic settlement options. Confidentiality is governed by applicable law, the parties’ agreement, and the mediation rules.

Mr. Hughes facilitates negotiations and communicates proposals between the parties. The objective is to determine whether the parties can reach a mutually acceptable resolution.

If an agreement is reached, Mr. Hughes may assist with documenting the settlement terms.

When the parties agree, they resolve the dispute on terms they accept. Mediation may also help preserve an ongoing construction project or business relationship when that is important to the parties.

If the dispute does not settle during the scheduled session, Mr. Hughes may continue working with the parties afterward to help address the remaining differences.