Preparing for Mediation
- Make a list of your Assets & Debts with approximate balances. If you don’t know, that’s ok. We will address this when we meet.
- Avoid “Digging In” to a position about on an unresolved issue. It’s OK to talk about issues with your spouse or ex-spouse before coming to mediation, BUT HERE’S A CAUTION: Arguing about issues can result in each party “Digging In” to a position and makes future negotiation difficult. You might be wise to wait until your first mediation session before you start negotiating.
- Consulting An Attorney: Some folks consult their separate attorneys before mediation. Others wait until a first draft of your Separation Agreement is prepared. If you intend to consult an attorney, we suggest that you find one who is “Mediation Friendly”. Many clients wait until after mediation is complete and review their Separation Agreement with separate counsel before signing it. YOU WILL NEVER SIGN ANYTHING IN OUR OFFICE. Agreements are mailed to you so you have the time to review them carefully.
- Review the Mediation Checklist below to see what topics apply to you.

Mediation Checklist
Issues Relating to Your Children
- Parenting Schedule (Lawyers call this “Custody & Visitation”)
- Legal Custody (Decision Making)
- Child Support (Required in Maryland)
- Health Insurance (Coverage for Children)
- Extra Medical Expenses (Not Covered by Health Insurance)
- Dependency Exemption (Tax Issues)
- Camp
- Private School
- College Education
- Extra Ordinary Expenses (Costs for Things Other Than Basic Needs)
- Parenting & Communication Rules
- Changing Residences or Restricting Moves Outside of the Area
- Introducing Children to Dates or Significant Others
- Parenting Schedule (Lawyers call this “Custody & Visitation”)
- Legal Custody (Decision Making)
- Child Support (Required in Maryland)
- Health Insurance (Coverage for Children)
- Extra Medical Expenses (Not Covered by Health Insurance)
- Dependency Exemption (Tax Issues)
- Camp
- Private School
- College Education
- Extra Ordinary Expenses (Costs for Things Other Than Basic Needs)
- Parenting & Communication Rules
- Changing Residences or Restricting Moves Outside of the Area
- Introducing Children to Dates or Significant Others
Alimony & Spousal Support
- Mutual Waiver of Alimony?
- Amount
- Duration Temporary or Permanent
- Modification in the Future
- Remarriage
Monetary Award & Issues for a Marital Property Settlement
- Lump Sum Payment
- Life Insurance
- Benefiting Children
- Benefiting Spouses
- Health Insurance
- Asset Allocation
- Bank Accounts
- Stocks & Bonds
- Retirement Accounts (IRAs, Pensions, Civil Service Retirement, Etc.)
- Qualified Domestic Relations Order (QDRO)
Personal Property
- Furniture
- Automobiles
- Boats & Planes
Marital Home
- Home Sold
- Home To Be Sold
- Buy Out By One Party
- Use & Possession w/ Buy Out
- Public Auction
Debts
- Division of Debt Responsibility
- Each Party Pays Own Debts
- Indemnification Clause
Tax Returns
- Joint Filing
- Separate Filing
- Deductions
- Exemptions
Counsel Fees & Court Costs
Other Real Estate
- Rental Property
- Vacation Home
- Second Home
- Time Share