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A mediation plan is a sequence of projected procedural steps initiated by the mediator that will assist parties to explore how they can reach common understandings or agreements.

In summary, the main elements of mediation are: 1 That it is voluntary in the sense that the parties participate of their own free will. 2 A neutral third party assists the parties towards a settlement. 3 The process is non-binding unless an agreement is reached.

I'm (Mediator's Name) and this is (Mediator's Name). We will be serving as your Mediators. You may call us by our first names; how would you like us to address you? The purpose of our meeting is to help you work out an understanding acceptable to both of you to resolve the situation that has been developing for you.

Start with a summary of who the parties are and what is at issue before getting into the facts and the details of the claims. Provide a concise summary of the facts and claims. The next section should provide details to help the mediator quickly learn the key facts and how they relate to what is at issue.

SAMPLE INTRODUCTION 2 Good morning, I am , from the mediation program. I am your mediator today, which means that I am here to help you and to aid your efforts to resolve your conflict. To help you, I will stress three things: One, your voluntary participation.

At this time, you will generally thank the parties for their time and effort in making the mediation successful. It may be a good idea to point out some of the more positive aspects of each party's involvement and show how those behaviors all came together to reach a positive resolution.

Key elements of mediation: Impartial skilled negotiator. Voluntary (on the part of the clients) Confidential. Informal and flexible. Decisions based on consensus. Focused on the future to achieve a 'gain-gain' result and resolve conflict.

A carefully drafted mediation statement can help a mediator plan strategy for a successful settlement. Be upfront. ... Provide a concise summary of the facts and claims. ... Summarize prior settlement discussions. ... Identify strengths and weaknesses. ... Bring it home.

It is not necessary to prove that one party is at fault. The most difficult part of the mediation process is to get people to accept that mediation can be an effective way to resolve their dispute. Most disputes tend to be very personal and some people want their day in court, whatever the cost.