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Saturday 24 November 2012

Opening Statement for Mediation


Dear all,

 
Opening Statement for Mediation

 
I am Natalia Cheung, an Accredited Mediator of the Hong Kong International Arbitration Centre and a practising solicitor in Hong Kong.
 

I would like to share with you the information which can be presented in the Opening Statement during mediation session from the perspective of a solicitor.
 

(1)    Introduce your teams

(2)   Summarize the background of your client’s case

(3)   Identify the issues in dispute—including factual disputes and substantive  laws

(4)   Emphasize the strengths of your client’s case and present it in the most favourble light

(5)   State your client’s concerns and needs

(6)   Focus on the present situation

(7)   Identify the implications of the disputes on both sides-liability and quantum, and in commercial and/or personal terms

(8)  State your client’s desire to work on a resolution of the disputes which is acceptable to both sides

(9)   State your expectation of the mediation

(10)  Address the opposite party directly instead of the mediator

(11) Use visual aid e.g. table, diagram, etc

(12)  Deal with the law, the facts, technical issues and the emotions of your clients

For further information on mediation, please contact Ms. Natalia Cheung 

[(852)-6777 5767]

E-mail: natalia@plaw.hk

 
Natalia Cheung 

HKIAC Accredited Mediator & Hong Kong Solicitor

Pang Kung & Co., HK Solicitors & Notaries & Civil Celebrants of Marriages
 
 

Disclaimer: The above is for your information and reference only. The contents do not constitute legal advice or a substitute for legal advice in individual cases.