Mediation Process

What Help Does Ron Friedman Provide During a Mediation Session?

Bringing in an experienced third party neutral to "mediate the dispute" changes the dynamics of the bargaining, exposes more possibilities, and can afford better opportunities for the parties to make the best choice. If you select Ron Friedman Mediations, you can expect that he will bring to the table invaluable knowledge about how others settled similar disputes and the patience needed to get the job done. Ron mediates with a facilitative style, but for more difficult cases, Ron offers neutral evaluation in caucus upon request; and, when requested by both sides, Ron has an impressive record of breaking inpasse and settling cases through "Mediator Proposals." During the session, he will provide all of the following mediation services and assistance:

  • Listen, acknowledge and validate his understanding of your positions
  • Help both parties to communicate their message effectively
  • Foster a more empathetic understanding of interests and concerns
  • Identify and clarify the decisive issues
  • Present the full force of your side's position with clarity and accuracy
  • Obtain genuine engagement at the heart of the matter
  • Discuss (in caucus) strengths and weaknesses of liability and damages arguments without taking sides
  • Explore the consequences of not settling [i.e., discuss the BATNA]
  • Find settlement options the parties did not recognize before
  • Stimulate the exchange of acceptable compromises¬†
  • De-escalate conflict and channel thinking to overcome obstacles
  • You will gain valuable insight into the settlement value of your case
  • If requested, he offers neutral evaluation, decision tree analysis and "mediator proposals"

Twelve Things You Can Depend Upon!


1. Through Preparation, Including a Careful Study of Briefs and Review of Cited Authorities

2. A Fair, Unbiased and Impartial Proceeding in Which You Can Achieve Your Reasonable Objectives

3. Non-Confrontational Private Meetings with the Mediator

4. A Businesslike Mediation Process that Promotes Dialogue and Understanding

5. Illumination and Use of the Wealth of Knowledge and Wisdom of the Gathering

6. A Mediation in which You Will Discover Your BEST Choices and Receive Help Evaluating Them

7. Use of Proven Strategies and Tactics to Overcome Impasse and Achieve Settlements

8. Assistance to Draft Enforceable Settlement Agreements

9. Reconciliations that Preserve Important Business or Family Relations by Solving the Dispute

10. Careful Protection of Confidential Communications at All Times

11. Strict Compliance with ABA's "Model Standards of Conduct for Mediators" And All Local Ethical Rules

12. Bottom Line: Most Cases will Settle Within an Acceptable Range for a Reasonable Cost