It can often be very useful for the mediator to have a pre-mediation confidential discussion with representatives of each party prior to the mediation – usually after reading the mediation bundle. In cases of high emotion it can also be useful for the mediator to have a pre-meeting with the claimant and or the claimant’s family.
In some cases it may be appropriate to have a joint telephone conference between the mediator and a representative on each side to discuss matters such as:
- any outstanding disclosure;
- exchange of position statements;
- up to date schedule exchange;
- who will be attending the mediation; and
- disabled access to the building when required.