Final review of Aisha's client-letter draft on mediation; light revisions; sent to Maria Martinez 2026-05-19.

Drafted client letter on mediation strategy and posture for Sarah's review; informal tone; addressed authority range and risk frame.

Senior review of motion-to-compel draft; structural edits to Sections III and IV; instructed David to add a footnote on Apex's pattern of meet-and-confer non-responsiveness.

Built mediator hand-off binder (mediation brief + 26 exhibits + key deposition excerpts); two clean copies prepared.

Drafted plaintiff's motion to compel — final Sections V and VI (sanctions request and proposed order); circulated full draft to Sarah and Aisha.

Cite-checked David's draft motion to compel (62 citations); two minor format corrections; otherwise clean.

Met-and-conferred (Zoom) with Jacqueline Nguyen (H&V) re Garcia deposition logistics — agreed protective-order scope, exhibit sequencing, 6-hour limit, downtown LA location.

Reviewed Aisha's M&C summary on Garcia deposition logistics; approved settlement on protective-order language; instructed Aisha to confirm in writing.

Reviewed full mediation brief draft (David + Aisha); structural edit; restructured opening; added closing settlement-rationale section. Circulated to client for review.

Drafted plaintiff's motion to compel Section III (privacy-log challenges) and Section IV (in-camera review request).

Garcia deposition prep: reviewed October 2024 personnel-file emails; refined witness outline focusing on Park's 'cleanup' instruction; cross-referenced with Park deposition pp. 142-167.

Updated Garcia exhibit binder with final pagination; pulled Park's deposition transcript excerpts (pp. 142-167) and tagged for the impeachment binder.

Strategy call with Maria Martinez re mediation brief content; addressed client's concerns about specific language describing the termination; agreed on framing.

Drafted plaintiff's affirmative motion to compel — Section I (introduction) and Section II (relevance and proportionality framework for the FMCSA bucket).

Drafted Section III of mediation brief (legal framework + burden-shifting); incorporated Lawson v. PPG framing; coordinated tone for non-litigator audience (mediator + opposing client rep).