CMN 4131 Lecture Notes - Lecture 5: Joint Resolution, Alimony

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Make sure parties are not facing each other (not obliged to stare at each other if they do not want to) Think about how the party will think or feel in this situation. Keep both parties levelled - for party imbalance purposes. Remind parties of your role as a mediator (neutral, previous agreements, parties make. Try to start with lighter topic to set the tone of the mediation their own ground rules to increase their ability to comply) Make sure that parties do not interrupt each other. Provide opportunity to talk until the end, uninterrupted. Ask open questions e. g. what happened to bring you guys here today? (do not bring up the issues) Do not steer the conversation at this time - just let them vent. Only steer conversation after both parties have vented - with facts in mind. Bring up positive facts up if tone is negative - e. g. bring up what was actually working in.

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