MICHAEL D. MARCUS’S MEDIATION MESSAGE NO. 87 COURT CONGESTION, MEDIATIONS AND THE THREE-YEAR AND FIVE-YEAR RULES In the halcyon days of adequate court-funding, little attention was given to Gonzalez v. County of Los Angeles (2004) 122 Cal.App.4th 1124, which holds that the five-year deadline to try a case is tolled when the action is submitted to mediation during the last six months of the five-year period. But since the three-year and five-year rules have again…