Construction & Infrastructure
Liens, delay and change-order claims, scheduling, subcontract and deficiency disputes. Built for Ontario's megaproject pipeline.
Mediation
That is the point of the role, and it is what makes the day work. I run the process, test each side's case against the documents, and keep it moving until there is an agreement or there plainly will not be one.
The role
I act as a neutral. I do not act for a party in a matter I take, and each party should have their own legal advice.
What I bring to a file is that I read the contract and the technical record underneath it — the change orders, the schedule, the model card, the system impact assessment — rather than either side's summary of them.
Formats
Chosen with the parties at engagement, not assumed.
Rules
The ADRIC National Mediation Rules. The ADR Institute of Canada publishes them. They cover initiating a mediation and appointing a mediator where the parties cannot agree on one, and the document carries a code of conduct, a standard form agreement to mediate, and a model dispute resolution clause for contracts. If the agreement already names them, the process is defined before anyone calls me.
Or a protocol the parties write. Where the contract is silent, or where the matter needs something a standard rule set does not contemplate, the protocol is settled in writing before the session.
Preparation
Confidentiality
Confidentiality is set by the agreement to mediate, and that is signed before the session rather than described on a website. The part worth settling in it explicitly is the caucus: what a mediator may carry from one room to the other, and how a party releases something for use. An agreement that leaves that implicit is the one that produces an argument on the day.
What a party tells me in caucus stays in that caucus until they tell me I may use it, and I do not carry a number across the hall that I was not given to carry.
Mediation is conducted on a without-prejudice basis. What that means for a particular file, and what survives it, is a question for each party's own counsel rather than for the neutral.
Subject matter
Where a mediation usually turns on something technical.
Liens, delay and change-order claims, scheduling, subcontract and deficiency disputes. Built for Ontario's megaproject pipeline.
Software contracts, SLA and MSA breakdowns, data residency and processing, AI vendor diligence, IP and licensing.
Connection assessment and approval, leave to construct, proponent–municipality disputes, and IESO market participation.
Accident benefits and SABS entitlement, MIG disputes, and private mediation retained by the parties, not the Tribunal's case conference.
Shareholder and partnership disputes, co-founder breakdowns, and business succession in family-held companies.
Diaspora business succession, dual-jurisdiction shareholder disputes, and cross-cultural commercial matters. Conducted in English or Farsi.
Fees
Half day and full day, including up to 2 hours of preparation in a half day and up to 3 in a full day. Additional parties, overtime and the cancellation schedule are on the rate card.
Next step
Tell me the shape of the matter and who is involved, and I will tell you whether I am the right neutral for it. Inquiries are answered within two business days.