Preparing the Position Statement

AuthorStephen Walker/David Smith
Pages215-217

Page 215

Appendix 3

Preparing the Position Statement1

Before mediation, the mediator will want to know some details about the case. He will not want or need to know about every single aspect, however gaining an insight into the facts, the issues and the interests of those involved will be key in helping to make the mediation progress effectively.

This document is a guide/checklist to help you to prepare your position statement. If you are unclear as to whether something is relevant and should be included, please discuss the matter with the mediator or with one of ADR Group’s mediation advisers.

General

• The parties’ names.

• Solicitors’ details.

• Names and titles/positions of the attendees.

• Date and location of the mediation.

Case summary

• Describe concisely the background to the case ensuring that the issues of liability and quantum are clearly set out. A list of the issues and/or a chronology of the key events is often helpful to the mediator.

• What are the key issues?

• What are the unique features that the mediator ought to be aware of?

• Have any...

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