Daniel
W. Winters, Special Master/Mediator
FEE SCHEDULE
Effective January 1, 2008
SPECIAL MASTER and MEDIATION SERVICES: $700
per hour
Rates include hearings, conferences, review
of briefs or documents, and research. To the extent
possible, the reading of day-to-day correspondence
and court documents will be performed by a paralegal
or clerical staff member. In addition, parties will
be charged for photocopies, telephone, fax services
and travel incurred in the handling of each matter.
RETAINER: $1500 per party
Required in advance of any mediation.
CANCELLATION AND RESCHEDULING POLICY
Cancellation or rescheduling of a scheduled Mediation
or Settlement Conference may be billed to the party or
parties requesting the delay as follows:
| FULL DAY: $3,000 |
(Within
48 hours) |
| HALF DAY: $1,500 |
BILLING POLICY
Unless otherwise agreed, fees for Mediation are
divided equally among all participants.
Fees for Special
Master or Discovery Referee services will be apportioned
based upon a number of factors, including the parties'
relative exposure, length of involvement in the matter,
contributions to settlement, time spent with individual
parties, relevant Court orders, and ability to pay. Fees
will be billed periodically or as otherwise requested
by the parties. 
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