Tips for the Opening Statement 

  1. Think of the message you want to get across. Conciliatory, confident, stress your strengths.
  2. Make it no longer than 10 minutes - don't waffle, keep your points concise.
  3. Remember you are not addressing the mediator like you would a Judge - he has read the papers, he probably understands the facts.  You have an opportunity to speak directly to the opposition and more importantly their client across the table, so make the most of it.
  4. Tell them the weaknesses in their case
  5. Finish on a conciliatory note.