MICHAEL D. MARCUS’S MEDIATION MESSAGE NO. 85 THE FRAUD EXCEPTION TO THE PAROL EVIDENCE RULE Occasionally, I’ve used Mediation Messages to write about topics that can impact trial issues and thus the quality of cases at mediation. (See Mediation Message no. 77 concerning the work-product doctrine and no. 67 regarding the conclusive effect of statements in pleadings.) Riverisland Cold Storage, Inc. v. Fresno-Madera Production Credit Assn. (2013) 55 Cal.4th 1169, which re-examined the fraud exception…