What Will We Discuss in Mediation?

Before we begin mediating, it can be helpful to think about the range of topics we might need to discuss so you can come into the first session somewhat prepared for what to expect.

Here’s a list of items we may need to cover as we discuss your separation agreement and / or parenting plan.

Keep in mind that this list is meant to encompass a wide range of situations and most couples won’t need to discuss all of them. You might find that many items don’t apply to your situation or that you’re in agreement about many of the topics.

Possible Mediation Topics

Property Allocation

Assets

  • Identification of all assets

  • Classification of assets as martial or separate

  • Evaluation and date for valuation of assets

  • Distribution

Martial residence

  • Who, if either, stays? If retained by one, what and when paid?

  • If to be sold, when? Sales price? Division of proceeds?

Other real property

  • Time share / weekend house – sell, share, or buy-out?

  • Acreage

Liquid assets

  • Bank accounts

  • Investments – mutual funds, stocks, bonds

  • Life insurance (cash value)

Retirement funds / pension

Employee benefits

  • Bonus / deferred compensation

  • Stock options

Business interests

Other property

  • Automobiles

  • Equipment

  • Livestock

  • Household furnishings / personal effects

Pets

Liabilities

  • Credit cards

  • Student loans

  • Other debts

Spousal assistance

Spousal support (maintenance / alimony)

  • Amount

  • Duration

  • Cost of living adjustments

  • Modification for future changes

  • Co-habitation definition, effect

Spousal health insurance

Tax ramifications

  • Capital gains issues (from sale of marital home or other assets)

  • Plans to file for current / future years 

Other financial issues

  • Life insurance: what is needed to underwrite future obligations?

  • Legal representation: utilized or waived?

  • Mediation, court, and counsel fees: how to handle?

  • Dispute resolution: mediation and / or arbitration clause for future issues?

  • Religious divorce: any provisions required?

Parenting Issues

Schedule

  • School evenings, weeknights, weekends

  • Three-day weekends

  • School recesses – winter, spring, summer

  • Holiday celebrations

  • Mother’s Day / Father’s Day / birthdays (parents and children)

  • Electronic access to children

  • Transportation between households

  • Travel away from home with children

  • Changes to the schedule at future times

Decision-making

  • Joint agreement, consultation, or sole authority for decision on:

    • Education

    • Extracurricular/weekend activities

    • Medical care (non-emergency or elective)

    • Religious upbringing

    • Child-care providers

    • Electronics / screen time

Access to information

  • Mechanisms for sharing information about the children

  • Receiving records and reports from physicians, dentists, etc.

  • Receiving reports and notices from schools, teachers, etc.

Protocols

  • Expectations for visits, cancellations

  • Standards for parental interactions

Relocation

  • Rules or adjustments for change of children’s residence

Survivorship

  • Interactions with family members if one parent passes away

  • Guardians in the event of the death of both parents

Significant others

  • Introduction of new partners to the children

Children’s expenses

Contribution towards basic needs

  • Calculation of needs: by budget or by CSSA guidelines

  • Adjustment upon emancipation of each child

  • Cost of living adjustments

  • Modifications at future time / upon each child’s emancipation

Educational costs

  • Extracurricular activities

  • Summer camp / activities / lessons

  • Private school tuition

  • College tuition and costs

Medical costs

  • Health insurance: whose plan? Who pays? What reimbursement procedures?

  • Uncovered expenses and deductibles

Child care

  • Costs for both parents to work

Child tax credits

  • Allocation of annual benefits

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What are my options for divorce in New York State and why might I choose mediation?