Preparing For Mediation

In most counties, some form of dispute resolution isSome clients find mediation more difficult than
required before your trial date. The most commondeposition because the mediator is judging your facts.
form of alternative dispute resolution (ADR) isIt's important to avoid becoming frustrated within the
mediation. Although some mediations take place withcourse of mediation even if the other side is behaving
all parties in the same room, most mediators prefer tounreasonably. Even if you do not settle, critical
have the parties separated in two separate roomsinformation can be learned during the course of the
and the mediator will go from room to room to discussmediation that may lead to settlement in the future or
your case.may be useful at trial.
It's important to note that offers of settlement are notDo not forget that the mediators job is to obtain
admissible as evidence in court. Therefore, informationsettlement. It is up to you and your attorney (not the
shared regarding settlement offers in mediation aremediator) to determine if the settlement is fair.
confidential. This is not to say that facts learned duringIf there is something you would like the mediator to
the course of mediation cannot be used at trial.know that you do not want the opposing party to
Anything you say at mediation outside of settlementknow, most mediators will keep information confidential
can be used against you.but you must ask them to do so. It is important that
Don't be shy regarding asking the mediator to leaveyou specifically ask the mediator about his or her
the room if you would like to discuss an issue privatelypolicy regarding confidentiality of issues. You want to
with your attorney. Good mediators will understandavoid disclosing facts to the mediator without
and will allow you to consult with your attorney at anyassurance that the fact will not be shared.
time.