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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. The mediation process exists for you benefit, which is why it can be voluntary.
Provide a concise summary of the facts and claims. The mediator will not have the patience or need to read an appellate brief. Avoid prose but use headings and bullet points to organize the section, and to summarize the claims, defenses and background about the parties.
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. The mediation process exists for you benefit, which is why it can be voluntary.
It may be easy to establish who is at fault, but you do not want to go into mediation saying things like, ?This is all your fault? or ?If not for you, I wouldn't have been injured.? Placing blame can raise the other party's guard, which could make them less likely to compromise.
The opening statements of the mediation process serve a number of purposes, and they are therefore necessary before moving on to the open session. For example, they allow the mediator to explain clearly the process to the parties.