The mediation agreement is a deceptively important document that is often not given the attention it deserves given that it creates the safe space for the mediation. 

 

All mediation agreements will provide that the process is confidential, but I have drafted one that confers greater protection to the parties.  My version allows participants to safely speak with stakeholders (such as funders or insurers) and experts without waiving confidentiality even if they are not present at the mediation day itself.  It also allows parties to safely share privileged documents with me without waiving privilege in them for any other purpose.   

 

You can download a copy of the agreement by pressing the link below.