"Never say more than is necessary."

Richard Brinsley Sheridan

Some examples of common ground rules used in mediation are:

• Each party will have an equal opportunity to speak

• Only one party will speak at a time.

• No interruption of the person speaking will be allowed.

• Listen as respectfully as possible.

• Try not to attack or put-down the person speaking.

• Use respectful language.

• No unproductive arguing.

• Each party is entitled to their own perspective.

• A party can request a break at any time.

• Unless there is an emergency, the parties agree not to engage in litigation while mediation is on-going.

• Both parties will work towards a constructive agreement.

• Responsibility for the resolution of the dispute rests with the parties not the mediator.

Since each mediation is different, so are the ground rules, but the above are fairly common minimums. Often agreeing on the ground rules sets the tone for the process and can be the first step in arriving at agreement on other matters.