Discovery Referee/Special Master

Katherine Gallo provides the following services as Discovery Referee/Special Master:

• Case Management Works with the parties in outlining the issues and coordinate a discovery plan. There will be scheduled hearing dates to coordinate discovery, to use as meet and confer sessions, as well as having discovery motions heard. The discovery referee/special master will work with the mediator and the settlement judge in directing discovery so settlement discussions can be productive.
• Tentative Rulings On the day prior to the hearing, all parties will be faxed tentative rulings and will have approximately three hours to notify the Discovery Referee of their decision of whether to contest the tentative ruling. All motion procedures are set out in advance and are code compliant except where the court or parties direct otherwise.
• Conference Call Hearings Hearings may be held via phone conferencing. At any party's request, an in-person hearing can be scheduled and will be held at a mutually agreed upon-location. In complex cases, the discovery committee will meet in person and the other parties have the option of attending in person or appearing via phone conference.
• Recommendation and Orders The Discovery Referee prepares all the recommended orders which will contain a ruling on every objection to each interrogatory, request for admission, request for documents or deposition question in issue. In addition, there will be a ruling on sanctions and referee fees. The recommended order will also specifically state that if any party objects to the recommended order, they must comply with C.C.P. section 643.
• On Stand-By For Depositions With appropriate notice, the Discovery Referee will be on phone standby to rule on objections during a deposition.
• Aim Toward Settlement Provides active assistance to the parties to obtain an experienced professional to mediate the matter or work with the court to obtain an early settlement conference.

Mediation

Katherine Gallo brings to the mediation a unique combination of practical experience, formal mediation training and a keen understanding of where the parties are coming from, enabling her to carve out creative resolutions satisfying all sides.

Types of cases Katherine Gallo has successfully resolved:

• Real Property (including eminent domain, easements and commissions)
• Personal Injury
• Product Liability
• Elder Abuse
• Construction Defect (including liens and construction operations losses)
• Employment (wrongful termination, discrimination, harassment and wage and hour claims)
• Professional Malpractice
• Business and Commercial Disputes
• Lemon Law

Ms. Gallo has extensive experience as a Pro Tem Settlement Judge or private mediator, with a settlement rate in excess of 90%.