A CONTRACTUAL MEDIATION PRECONDITION REQUIREMENT AND AN AWARD OF ATTORNEY’S FEES Lange v. Schilling (2008) 163 Cal.App.4th 1412 holds that a party to a contract which provides that to receive attorney’s fees and costs a prevailing party must first attempt to mediate the matter before commencing arbitration or a court action may not receive such fees for failing to comply with that condition precedent. The parties in Lange v. Schilling used a standard California residential…