the opening statement should contain about eleven elements: Introduction of the mediator, and if appropriate, the parties Commendation of the willingness of the parties to cooperate and seek a solution to their problems and to address relationship issues. Definition of mediation and the mediator’s role. Statement of impartiality and neutrality Description of the proposed mediation procedures Explanation of the concept of the caucus Definition of the parameters of confidentiality Description of the logistics, scheduling, and length of meetings Suggestions for behavioral guidelines or ground rules.
10. Answers to questions posed by the parties
11. Securing a joint commitment to begin.