Divorce Mediation and Arbitration - How to Stay Out of Court

Before entering into mediation or arbitration, you needthe mediation to work because he will make a lot
to know the difference between them. In arbitrationmore money if we cannot settle." Again, the better
and mediation, a neutral third party is used. But this islawyers would be pleased to see their clients avoid
where the similarities end. In arbitration, both husbandthe trauma of a contested divorce. These topnotch
and wife agree to give the arbitrator the power tolawyers want what is best for their clients.
decide the dispute as a judge would. In bindingMediators come from different professions: mental
arbitration, you agree beforehand to abide by thehealth, financial planning, law, or social work. Most
decision as if it were law. In straight arbitration, if youimportant, however, the person must have training in
don't like it, you can go elsewhere.mediation, and be knowledgeable about issues
The purpose of mediation is for both husband andconfronted in a divorce.
wife to come to a mutually acceptable settlement. TheYou'll also want to focus on the mediator's style, and
mediator does no individual counseling, and is limited todecide which will work best for your situation. Some
gathering data, setting the ground rules, and keepingwill simply be a third party to facilitate communications
both parties on track. Throughout mediation, alternativeas you and your spouse sort through issues. Others
solutions are offered, issues are clarified, and awill provide advice about particular issues such as child
settlement is arrived at. If you and your spouse arecustody or property division. And still others will assist
communicating, then mediation should be explored.the parties in working through some of the emotional
Mediation as a Choice Mediation doesn't eliminate yourissues of divorce.
need for a competent lawyer. It does require voluntaryIn shopping for a mediator, ask the following questions:
participation of both husband and wife.
Mediators can be retired or active family law1. Do you specialize in family law?
commissioners or judges, a lawyer who is skilled in2. How many mediation cases have you handled in the
family law, or a lawyer who is skilled in family law andpast 12 months?
has some counseling background. Mediators can also3. How long have you been a mediator?
be psychologists or other professionals who have4. What kind of training do you have?
been trained in mediation.5. Do you have any certifications?
Gary Friedman is a lawyer and director of the Center6. What is your professional background?
for Mediation in Law, located in Mill Valley, California. His7. How much do you charge and how do you bill?
book, A Guide to Divorce Mediation (Workman8. Do you see the parties individually or only as a
Publishing, 1993) is one of the best on the marketcouple?
today. Since the early 1980s, he has trained thousands9. What is your schedule like for the next two weeks?
of lawyers in the skills of mediation. When we first10. What guidelines or checklists do you use to make
spoke with him, we asked if one of the objectives ofsure you address all issues?
mediation was to attempt to get couples through the11. Are you aware of how courts in this country
divorce process with the least amount of pain. Hisresolve certain issues such as child custody and
response was, "In many ways, mediation is morespousal support, and does that influence you?
painful than divorce because you face each otherA goal of the mediation process is to draft the outline
directly. You experience conflict in a very intense way,of a settlement. The parties will then have a lawyer
so that in terms of what you go through, many timestake the outline and prepare a formal separation
mediation is harder. Mediation is a face-to-faceagreement based on the terms of the mediation. If you
situation -- both parties often hear things they don'tare using only your spouse's lawyer in your case, seek
want to hear."a second opinion from your own lawyer. Have this
He stated that plenty of lawyers support the mediationlawyer explain the pros and cons and significance of
process but added that many only pay lip service to it.each provision. Remember, you will have to live with
"Most lawyers are quite attached to law as thethis the rest of your life.
standard to be used in determining how people shouldArbitration Arbitration is another tool for avoiding
decide their disputes and don't believe that such a thinglengthy and expensive litigation. An arbitrator acts as
as fairness exists," he said. "When mediation is broughtyour own private judge who conducts a "mini-trial" of
up, many lawyers are very cynical about it."sorts, in which the parties and their lawyers present
Why? Money is one good reason. Mediation costs atheir cases. Arbitration is used more in some areas
fraction of what it would for standard lawyers to workthan in others, and can be particularly attractive if you
out the settlement. It is charged on an hourly basis andlive in an area with a huge backlog of cases. If you
it usually takes from four to ten sessions for couplesagree in advance to what is called binding arbitration,
to get through the whole process. Friedman said thatthe arbitrator's decisions are final and become a court
the best lawyers and the most competent divorceorder just as if you had gone before a judge. On the
lawyers have no problems when their clientsother hand, you can agree that the decision of the
participate in mediation. In fact, they actually encouragearbitrator is only "advisory," in which case you would
them to do it, know how to support them as they gonot be required to follow his or her decision.
through the process, and encourage them to comeAn arbitrator can be used for the entire process or
back and consult. "This way, the husband and wifeonly to resolve certain issues. The arbitrator may even
have the protection of their lawyers and, at the sameoffer a combination approach, mediating initially, but
time, the ability to control the decisions that are made inmaking a decision for you if you cannot agree.
meetings face-to-face with spouse," he said.Shop for an arbitrator in the same way as you would
This is not to say that lawyers have no place infor a mediator, but you will find that it is rare that an
mediation; the contrary is true. A good lawyer will helparbitrator is not a lawyer. Retired judges frequently
you guard against one of the dangers of mediation -open arbitration practices. If this is something you want
that this more informal approach could miss orto consider, ask your lawyer to recommend some
inappropriately value properties that are divided in thegood arbitrators.
marital settlement. Before you sign any agreementsIn some jurisdictions the court, upon request, will
that come out of mediation, have them reviewed toapprove a lawyer to act as what is called a "special
determine whether they represent your best interests.master" to get past a problem area. This appointed
The bottom line is that no single person has all thelawyer usually will have a particular area of expertise,
answers and any answers he or she offers will oftensuch as the division of pensions. Again, your lawyer
be muddy. Some type of compromise may well beshould play a significant role in deciding whether to use
the only solution. In reviewing our files of men anda special master and who that person should be.
women who achieved successful divorces - fromWe are not thrilled when we hear that divorcing
which they came away with their self-esteem intactcouples are gearing up for a courtroom encounter. It's
and a reasonable property settlement - we noticedrare for both sides to come out of the courtroom
two key similarities: They had a nonadversarial lawyercontent with the aftermath of a divorce. If you feel
representing each side and they kept channels ofthat you may be caught up in someone else's agenda
communication open.- yes, lawyers sometimes do not act in your best
How to Make Mediation Work Obviously the selectioninterest - consider strongly getting a second opinion
of the mediator is critical if this process is to be given aand input from one of the experts identified here.
chance to work. An experienced divorce lawyerPoints to ponder:
(another time when experience counts) in aBe sure you understand whether the arbitrator's
metropolitan area will know a variety of mediators withdecision will be binding or only advisory.
varying backgrounds and strengths. GetThere is no lawyer-client privilege with a mediator,
recommendations from your lawyer before you turnarbitrator, or special master, so anything you say could
to other sources.come out in court.
You may be thinking, "I bet my lawyer does not want