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Mediation NYC311 Using this site or communicating with Walters Gilbreath, PLLC through this site does not form an attorney-client relationship. For example, a possession schedule may be a non-negotiable for a client. Not paying spousal maintenance may be another non-negotiable. If there are issues that are merely non-negotiable for the client, they should be brought up before the mediation, so the lawyer knows how to approach those issues strategically. The mediator can help you overcome obstacles to communication with the other person or party in your dispute. Amazingly, lawyers often fail to explain the mediation process to their clients, which causes them to walk into the process uneasy and unprepared. If you are represented by a lawyer, you and your lawyer will decide how the two of you will interact during the mediation. Some lawyers instruct their clients not to talk during mediation. In med-arb, a mediation-arbitration hybrid, parties first reach agreement on the terms of th