COMPELLING A MEDIATOR TESTIMONY California state courts allow only express waivers and potential due process violations as exceptions to mediation confidentiality. (Simmons v. Ghaderi (2008) 44 Cal.4th 570.) Although the federal courts in California are less restrictive regarding the scope of such confidentiality (see Mediation Message No. 55), they still, as a generality, only waive the concept in limited circumstances. California finds the confidentiality provisions of Evidence Code section 1119 to be less important than…