Good afternoon gentlemen. My name is and I will be your mediator for today’s session.

Before we begin, I am pleased that the parties have chosen mediation and would like to
thank you both for agreeing to be a part of this process.

Could both the parties please introduce themselves.

CUE INTROS

Mr.A , Mr. B, I welcome you both to this mediations session. As per your request, I have
scheduled today’s session for 10 minutes. I hope that we are able to work out a solution
during this time. If not, we can schedule another session and continue the conversation.

Having chosen mediation as your preferred means of dispute redressal, I am sure you
must be aware of the benefits it carries over traditional methods like approaching a
court of law, benefits that include but are not limited to speedy redressal,
confidentiality and finally that it is a more amicable process and helps rebuild your
relationship.

Now, let me take this opportunity to guide you through the process.

Mediation is a client driven process which effectively means that it’s the two that will
work towards a solution. I am just here to facilitate the process and navigate the
conversation towards a solution.

I am a neutral party and I have no vested interest in this matter. the entire process is
non-prejudical towards both parties and nothing you say or agree to here is binding on
either party unless the parties agree to sign a settlement agreement.

All discussions with a mediator are confidential. Therefore, information will

only be shared with the express agreement of the parties.

The process of mediation also provides for a private caucus. If at any point either of you
feel the need to have a private conversation w me, you can request for a caucus.

Finally, if we arrive at a solution which is agreeable to both parties, and I hope we do,
we pen the terms down in the form of a settlement agreement which will be binding on
both parties.

Now, I understand that you are currently not at the best of terms and might be
overpowered by emotions, but I request both of you to be respectful of each other and
to not interrupt the party that is speaking.

if either of you have any concerns so far, I’ll be happy to address them
Very well, gentlemen.

Mr.A, you being the requesting party. Lets begin the conversation w your opening
statement.

RECAP AND SET AN AGENDA

Is there anything you would like to add to this?

Gentlemen I do not believe that this conversation is headed towards a solution. Let me
suggest something here