California, United States of America
The following excerpt is from McLaughlin v. Superior Court, 140 Cal.App.3d 473, 189 Cal.Rptr. 479 (Cal. App. 1983):
These conclusions permit the mediation proceedings which Civil Code section 4607 requires where child custody or visitation are contested. They also permit the mediator to make a recommendation to the court if the proceedings do not produce agreement, but only if the parties are guaranteed--or waive--the right to cross-examine the mediator and other rights essential to due process. (See Fewel v. Fewel, supra,
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