The first private session with the mediator is an opportunity to take stock after an opening meeting if there has been one.
This is an opportunity for the mediator to discover more about the case, what your client wishes to achieve and how you think it can best be done.
The session with the claimant side may well be longer than the defendants as the claimant often wants to discuss their injuries and losses and how it has impacted them. This is an important part of the mediation process.
You should identify what information you still need from the other side and discuss with the mediator the best way of getting it – in further joint sessions; meetings with the lawyers or the mediator shuttling between rooms.