1. Identify issues(s)

a. what are all of the issues?

b. identify the main issue in dispute

c. which issues will you focus on? which issues will you ignore?

2. Identify positions

a. define position

b. state the first party's position

c. state the second party's position

3. Identify interests

a. define interest

b. state the first party's interests

c. state the second party's interests

4. Describe your mediation plan

a. state your hypothesis of the cause/causes of the conflict

b. explain your strategy for how to approach the dispute and the specific interventions you plan to use

c. explain how you would "set the stage" for this particular dispute

d. state how you would frame the issue

e. explain how you will help the parties develop options

5. Creating options

a. brainstorm 5-8 possible options to resolve the main issue in dispute
Note: Be sure that they are separate options and not just variations of one option. Please have a few options that are creative; in other words, expand the pie and/or think "outside the box". Do not put these options in any particular order.

6. Judging options

a. rank the options from best to worst

b. explain your rationale for your best option

c. explain your rationale for your worst option

7. Objective Criteria

a. define objective criteria

b. list at least three examples of objective criteria applicable to this case

8. BATNA

a. define BATNA

b. state the first party's BATNA and explain the costs and benefits of it

c. state the second party's BATNA and explain the costs and benefits of it

d. explain how each party's BATNA influences the final result

9. Nailing Down the Agreement

a. write a specific and detailed memorandum of agreement based on your best option

b. explain how the parties will handle future minor problems

c. define failure of the agreement and the steps parties will take in the event the agreement fails