How To Prepare for Divorce Mediation

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How To Prepare for Divorce Mediation

Are you wondering how to prepare for divorce mediation?

Prior to attending any mediation regarding divorce or child custody, you should put together three lists. Here’s everything you need to know.

Tips on How to Prepare for Divorce Mediation

Here are three lists you should put together when you prepare for divorce mediation.

1. Your Best-Case Scenario

Your first list should be your best-case scenario.  This is everything you want to get at divorce mediation, no matter how unrealistic you think that list is.  This does not mean unicorns and rainbows, but your perfect parenting time schedule for you.  It should state what holiday schedule would be best for you, including exact times.  It should make you consider what child support amount you really want to receive or feel would be perfectly reasonable and in your children’s interest to pay.  Remember that this is your perfect world, and you should not consider whether or not your ex will agree with any of the items on this list.  This list will help you understand and itemize what you really want.

2. Your Settlement

Your second list should be what you believe the settlement should be.  This list is different than your perfect world list.  In the list, you are to go over all of the same issues, but you are to look at them in a different manner.  In this list, consider what is fair to yourself, your children, and your ex under the unique circumstances of your family.  This list will be much harder to make, as you need to force yourself to consider that all of your desires may not be reasonable.

3. Your Bottom Line

Your final list is your “bottom line” list.  This list is again to go over all of the same issues but needs to indicate the minimum in each area that you are willing to accept.  This is the hardest list for most people to make, but is just as important as the other two.  It will help you establish your boundaries.  In mediation, boundaries are necessary to help you avoid agreeing to things that you do not want.

Once you have completed the lists, you are NOT to show them to the opposing party or the divorce mediator.  They are for you.  They are now your study guide.  You know what issues are most important to you, what you want, and what your boundaries are.

Each list should be very detailed and address all of the following issues that apply to you:

Your Children

  • Legal Custody
  • Daycare/Payment
  • Grade School/Payment If Private
  • School Year Parenting Time
  • Summer Parenting Time
  • Holiday Parenting Time
  • Vacation Parenting Time
  • Should Child Have A Passport/Who Holds It
  • Extra-Curricular Activities/Payment
  • Religion
  • Religious Education/Payment
  • Religious Special Ceremonies/Payment
  • Mental Healthcare for Child
  • Pediatrician/Dental
  • Child Support
  • Telephone Contact


  • Marital Home/Value
  • Motor Vehicles/Value
  • Vacation Homes/Time Shares
  • Bank Accounts
  • Retirement Accounts
  • Personal Property
  • Furniture
  • Appliances/Electronics
  • Photographs
  • Pets
  • Collectables
  • Health Insurance
  • Car Insurance
  • Alimony
  • Marital Award
  • Marital Debt
  • Taxes
  • Any other property or debts

If you’re unsure of how to prepare for divorce mediation, take the time to do your research and really think about what you want to address. On the day of mediation remember that you are not there to impress the mediator.  You should always wear comfortable clothing and bring anything with you that you feel will help support you.  Although the mediator will typically have a pen and paper available to you, bring your own, just in case.

During the mediation, you are not required to agree to anything.  If it is a court-ordered mediation, you are only required to be present and follow the rules stated by the mediator.  If you need a break, ask for it.  You are not a prisoner, and you should not feel pressured into anything other than listening and maintaining a non-hostile demeanor during the process.

At the end of the mediation, if there are any agreements, they should be written up by the mediator. Do not sign anything until you have had an opportunity to sleep on it and, if possible, review it with an attorney of your choice that has your interests as their priority.  A mediator is not allowed to give you legal advice and the decisions made may not have been in your best interest or legally fair to you.  That is why you should always review the agreement with your attorney prior it becoming an official agreement/contract/order.

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