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Labor/Employment,
Class Action,
Alternative Dispute Resolution

Aug. 15, 2025

Pre-mediation strategies to win class and PAGA cases

Mediation in class and PAGA cases is essentially inevitable, so attorneys should prioritize early and thorough preparation -- including client management, data analysis, team-building and pre-mediation discovery.

Barbara DuVan-Clarke

Senior Trial Attorney and Team Lead
Blackstone Law APC

Phone: (310) 622-4278

Email: bdc@blackstonepc.com

See more...

Danielle L. GruppChang

Senior Associate
Blackstone Law, APC

See more...

Pre-mediation strategies to win class and PAGA cases
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Mediation is a relative inevitability for class and PAGA matters. The question is not "if" but "when and with who." Given that mediation is always on the horizon, attorneys on both sides should work up cases early and prepare thoroughly for what lies ahead. As soon as defense counsel receives notice of a wage and hour lawsuit, they should connect with their clients to prepare documents for production. Employers are unlikely to maintain employees' time and pay data in a form t...

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