the opening statement should contain about eleven elements:
- Introduction of the mediator, and if appropriate, the parties
- Commendation of the willingness of the parties to cooperate and seek a solution to their problems and to address relationship issues.
- Definition of mediation and the mediator’s role.
- Statement of impartiality and neutrality
- Description of the proposed mediation procedures
- Explanation of the concept of the caucus
- Definition of the parameters of confidentiality
- Description of the logistics, scheduling, and length of meetings
- Suggestions for behavioral guidelines or ground rules.
10. Answers to questions posed by the parties
11. Securing a joint commitment to begin.