At mediate.com Dave Ezra provides good advice on writing to persuade mediators and other participants in mediation. He starts: "In many cases it is the mediation briefs -- the overlooked briefs that are often
hastily prepared at the last minute -- that are the most important briefs."
"Remember one thing -- mediators read the concluding sections of mediation
briefs. Some might even read them first, before they look at any other part of
the brief."
More on Written Position Statements in Mediation here
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