I vary the mediation format and philosophies I use based on the parties and based on the case. I also vary it based on input from you.
This is one reason why I spend so much time preparing for each mediation in advance by reading the briefs and speaking to each side.
In some cases, I may ask you if you are amenable to our having joint sessions with lawyers only or with everyone. In other cases, I won’t do that. But in all cases, my goal will be the same: “concentrate on the merits of the problem, not the mettle of the parties.”
To get to yes.