Bryant Dispute Management

Preparing for Mediation

I have found it quite useful for parties (through counsel, usually) to submit to me a short memorandum setting forth the important issues that need to be resolved at the mediation if a resolution is to occur. I'm not looking for a brief limited solely to legal issues, but a candid statement of the perspectives regarding the dispute. The memo might include your views as to what has created the present impasse, ideas for facilitating a full and open exchange, and proposals for meeting your goals. You may think some of this information is best given to me in confidence. In that case, I urge you to submit two memos--one sharing important factual and legal issues with each other, and a supplement for my private review.