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<xTITLE>Sample Mediation Ground Rules</xTITLE>

Sample Mediation Ground Rules

by James Melamed
August 1998 Jim Melamed
Mediators often assist the parties to develop guidelines or ground rules to help support productive communication during a mediation, such as the following:

1. We agree to take turns speaking and not interrupt each other.

2. We agree to call each other by our first names, not "he" or "she."

3. We agree to not blame, attack, or engage in put-downs and will ask questions of each other for the purposes of gaining clarity and understanding. 4. We agree to stay away from establishing hard positions and express ourselves in terms of our personal needs and interests and the outcomes that we wish to realize.

5. We agree to listen respectfully and sincerely try to understand the other person's needs and interests.

6. We recognize that, even if we do not agree with it, each of us is entitled to our own perspective.

7. We will not dwell on things that did not work in the past, but instead will focus on the future we would like to create.

8. We agree to make a conscious, sincere effort to refrain from unproductive arguing, venting, or narration, and agree to use our time in mediation to work toward what we perceive to be our fairest and most constructive agreement possible.

9. We will speak up if something is not working for us in mediation.

10. We will request a break when we need to.

11. While in mediation, we will refrain from adversarial legal proceedings (except in the case of an emergency necessitating such action).

12. We will point out if we feel the mediator is not being impartial as to person and neutral as to result.

© 1996-2001 The Mediation Center, Inc. - All Rights Reserved


Jim Melamed co-founded in 1996 and has served as CEO of ever since. received the American Bar Association's 2010 Institutional Problem Solver Award.

Before, Jim founded The Mediation Center in Eugene, Oregon in 1983 and served as Executive Director of the Academy of Family Mediators (AFM) from 1987 to 1993. Jim was also the first President and Executive Director of the Oregon Mediation Association (1985-86). Jim's undergraduate degree is in in psychology from Stanford University and his law degree is from the University of Oregon.Jim has received the following awards: The Oregon Mediation Association's 2003 Award for Excellence; The Oregon State Bar's 2006 Sidney Lezak Award of Excellence; The Association for Conflict Resolution (ACR) 2007 John Haynes Distinguished Mediator Award; and The 2012 Academy of Professional Family Mediators (APFM) "Getting To Yes" Award.

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