The following checklist is designed to help you prepare for mediation by clarifying your goals and priorities in advance of the session. Please take a moment to answer these questions for yourself.

1. Interests (i.e., hopes, goals, needs, concerns, motivations) – What interests are you hoping to have satisfied at the mediation? What do you think is important to the other party? Imagine the mediation were a success - what goals of yours would be met as a result?
    
2. Options for agreement - What would be considered a good outcome for you and for the other party? If you were not a party to this dispute and you were asked to suggest some options for resolution that all parties might accept, what would you propose? (These possible terms should meet the interests of all parties.)
    
3. Alternatives to reaching an agreement - What will you do if you do not reach an agreement with the other party? What do you think the other party will do if an agreement is not reached? How well do you think these separate outcomes meet your interests compared to what you might do together?
    
4. Objective Standards (examples include - laws, precedents, industry norms) - What standards of fairness apply to your situation? How do you think a neutral (arbitrator, court, administrative judge, etc...) would rule on your matter and why? What have other people in your industry done when faced with a similar situation?
    
5. Communication - What messages do you want to send and have understood by the other party? What questions do you have for the other party at the mediation? What do you think the other party wants you to understand?
    
6. Relationship – Define the quality of the relationship between the parties. Should it continue or end? On what terms should it continue or end?
    
7. Commitment - Are you prepared to enter into an agreement? Does the agreement have to be enforceable from your point of view? Do you need to check in with anyone else before committing to an agreement?
    
8. Other - Please identify any other issues that you think need to be discussed. It's sometimes helpful to think of the mediation as a meeting and it's your job to create an agenda that will cover the topics that you think need to be addressed.
   
   

For more information, please contact your case manager at Mediation Works Incorporated 800-348-4888 or send an email to mwi@mwi.org.