Footnote 253

ADA Mediation Guidelines, 2 Cardozo Online J. Conflict Resol., § I(D)(4) (2001) ("If, despite support, a party lacks capacity to participate in the mediation, mediation should not proceed unless a surrogate participates in the process to represent the interests of the party and make the mediation decisions in place of the party."), at (last visited May 14, 2003).