Getting Ready for Family Mediation: Your Issues List, Goals, and Negotiation Boundaries
Mediation is often most productive when the “homework” is done before anyone joins the room (virtual or in person). Preparation does not mean arriving with a speech or a perfect answer for every topic. It means knowing what decisions must be made, what information is missing, and what a workable agreement needs to include.
This post provides a practical framework to prepare for mediation—especially helpful for people in Grande Prairie, Red Deer, Northern Alberta, and rural communities using a virtual process.
1) Start with an issues list (the agenda)
An issues list is simply a clear inventory of what must be decided. It helps prevent the common problem of spending most of the session on the easiest topics while the hardest issues are left for the last 20 minutes.
A typical mediation issues list might include:
Parenting
regular parenting schedule
holidays, birthdays, and special days
exchanges (where, when, and who transports)
decision-making (education/medical/extracurricular)
communication rules (including frequency and method)
travel, passports, and notice requirements
how future disputes will be handled (return-to-mediation clause, parenting app, etc.)
Support
child support (including income information needed)
special or extraordinary expenses (how they are approved and shared)
spousal support (if applicable)
start dates, payment dates, and proof of payment method
Property and debt
list of assets and debts
what needs valuation (home, pension, business, rural property)
whether the home is sold or refinanced; timelines
equalization/payment schedule approach
responsibility for joint debt and steps to close accounts
Practical tip: If the issues list is long, it is often more effective to plan staged mediation (two or more shorter sessions) rather than trying to resolve everything in one sitting.
2) Move from “positions” to “goals”
A position is usually a single outcome (“I want week-on/week-off,” or “I won’t pay spousal support”). A goal is the underlying need (“I need predictable childcare coverage,” or “I need a transition period to become financially stable”).
Mediation often becomes more workable when each person can describe:
what they need in the short term (0–3 months),
what they need in the medium term (3–12 months), and
what they want stabilized long term (12+ months).
This is particularly useful in parenting cases where children’s schedules evolve, and in financial cases where temporary support and staged property steps may be realistic.
3) Set negotiation boundaries (without painting yourself into a corner)
A negotiation boundary is not a threat. It is a personal decision about what terms are acceptable.
A practical way to set boundaries is to write down:
A) Non-negotiables
Examples (not universal—these depend on the facts):
“Any parenting plan must include safe exchanges.”
“No final support agreement without full income disclosure.”
“No agreement signed the same day it is first drafted.”
B) Preferences
Examples:
“I would prefer exchanges at school/daycare.”
“I would prefer email for communication.”
“I would prefer a schedule that minimizes midweek transitions.”
C) Trade-offs you can live with
Examples:
“If the holiday schedule is more generous, I can be flexible on one weekday evening.”
“If support is paid reliably by automatic transfer, I can accept a simplified expense-sharing process.”
4) Identify information gaps (and decide how to fill them)
Mediation stalls when parties negotiate “in the dark.” Before the session, identify what information is needed to negotiate fairly and efficiently.
Common gaps include:
unclear income (self-employment, seasonal work, overtime, bonuses)
missing tax documents or Notices of Assessment
incomplete debt lists
unknown pension values
uncertain home value (especially in changing markets)
lack of childcare/medical expense documentation
unclear parenting history and current routine
Practical tip: It is often better to spend a week organizing disclosure than to spend a mediation day arguing about what should be produced.
5) Plan the structure of the day (especially for virtual mediation)
A simple plan reduces conflict:
confirm the session length and break schedule
decide whether to begin with parenting or finances
decide whether a joint session is workable or whether shuttle format is needed
confirm how documents will be shared (secure link, email, screen share)
plan where each person will sit so the session is private and uninterrupted
For rural and Northern Alberta clients, virtual mediation can be an access solution, but privacy and pacing need to be intentional.
6) Put “implementation” on the agenda early
A good agreement is not just about what the parties “agree in principle.” It is about how it will actually be carried out.
Examples of implementation terms to consider:
deadlines for exchanging documents
exact payment dates and method
how expenses are approved and reimbursed
when the home will be listed or refinanced
who drafts the first version of the agreement
review dates and dispute-resolution steps
Implementation terms are often what prevent repeat conflict later.
7) Where pay-as-you-go legal support can help
Preparation is where limited-scope legal services can add significant value—particularly for families using mediation without lawyers present.
Virtual, pay‑as‑you‑go support can include:
a coaching call to turn concerns into a clear issues list and agenda,
support calculations (child support and, where applicable, spousal support),
disclosure planning and document organization guidance,
drafting a parenting plan framework so mediation time is used efficiently, and
drafting or reviewing a separation agreement after terms are reached.
Consult call: $100. To request an intake link, email jessica@kochsolutions.ca.
8) If mediation doesn’t resolve everything: litigation as the backstop
Mediation can still be worthwhile even if it does not resolve every issue. When an issue cannot be resolved—especially where disclosure is missing or urgent child-related concerns exist—court can be the backstop for enforceable interim orders, disclosure, and final decisions. Many cases continue negotiating and settle after a court file is started.
FAQ
1) What should be brought to a family mediation session?
A clear issues list, key dates (children’s schedules, work shifts), and any documents needed for support or property discussions (income information, debt lists, property documents).
2) How should priorities be set before mediation?
Identify what must be resolved now (temporary parenting/support), what requires more information (disclosure/valuations), and what can be staged with timelines and review dates.
3) Should proposals be shared with the other person before mediation?
Often yes, particularly if exchanging proposals reduces surprise and helps the mediator structure the agenda. In some cases, sharing proposals in advance may not be safe or productive—process design matters.
4) Can a parenting plan be drafted before mediation?
Yes. A draft can save time by giving the mediation something concrete to edit and improve, provided both parties understand it is a starting point, not a demand.
5) What if I feel pressured to agree during mediation?
It is appropriate to request a break, ask to move to shuttle format, or pause the session to obtain advice and consider options. Durable agreements require voluntary, informed consent.
Alberta resources
Alberta resources (helpful starting points):
Government of Alberta – Family Mediation: https://alberta.ca/family-mediation
LawCentral Alberta – Family Mediation Services: https://www.lawcentralalberta.ca/en/family-mediation-services-alberta-courts
Parenting After Separation (Alberta): https://www.alberta.ca/pas
Note: Family law and court processes can differ by province and territory. If guidance is needed for a specific jurisdiction, contact a local lawyer or the local courthouse for province-specific information.