Generally, my family mediation is conducted as follows:

1. After I pre-screen the parties, I encourage them to each have separate lawyers (if they don't already).

2. Following my initial meeting with their lawyers in the absence of their clients, I have my first joint meeting with the parties.

3. I then have an individual meeting with each party separately, following which I have further joint meetings with the parties.

4. In some cases, I interview the children separately from their parents.

5. In appropriate cases, I will meet with new partners.

6. I meet with both lawyers from time to time as needed.

7. When the parties reach an agreement, I prepare a Memorandum of Understanding. After I have reviewed the draft with the parties, I send it to their lawyers to review with the clients. Once everyone is content with the Memorandum of Understanding, it becomes the Separation Agreement

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