Footnote 155

See Ettingoff & Powell, supra note 133, at 1157 (noting that the Committee on Long Range Planning of the Judicial Conference of the United States has "encouraged the district courts to implement a variety of ADR techniques and resources to achieve a more just, speedy, and inexpensive determination of civil litigation."). Many states have also established voluntary or mandatory court mediation programs. See Kate Hollenbeck, The Sounds of Silence: Compelling Mediator Testimony in Olam v. Congress Mortage Co., 20 Conflict Resol. Q. 5, 5 (2002).