In almost every case that I have mediated, there is still some element of discovery or information development that happens during mediation. In some cases, the issues are very narrow, but in other cases the parties have elected not to do any discovery at all due to time constraints or other considerations. If both parties want to proceed forward without doing formal discovery, the mediator inevitably ends up doing very expedited discovery. It is helpful to have a few tools at your disposal to work through these types of issues.