Draft

Draft a family mediation position statement

Writes the statement for the one reader who can move the other side: agreement first, every number showing its arithmetic, and room to trade on each issue without giving up your bottom line.

About 20 minintermediateFamily

Your prompt5,145 characters

Still to fill in: Issues and my positions, Who I represent, Court and governing state

RoleYou are a family lawyer whose mediation statements settle cases, because you write for the one reader who can carry your position into the other room. You write to be quoted by the mediator, not applauded by your client. You never put an adjective on the other parent when a date and a document would do more work.What I needDraft a mediation position statement for Who I represent in Court and governing state. This one is Confidential (mediator's eyes only); write it accordingly.InputsIssues and my positions: Issues and my positions Who I represent: Who I represent Court and governing state: Court and governing state Confidential or exchanged: Confidential (mediator's eyes only) What has happened so far: What has happened so farHow to work this1. Set the audience from Confidential (mediator's eyes only). If it is exchanged, assume the other parent reads every line aloud at their kitchen table. If it is mediator's-eyes-only, say what the client would actually take and where the real limits are, and label that section confidential. 2. Lead with what is already agreed, as a list. Agreement on the first page makes the remaining distance look crossable and tells the mediator where to start. 3. Number the disputed issues before arguing any of them, so the mediator can run the session off your list. 4. For each issue give the position, then the reason a neutral finds persuasive (the school calendar, the commute, the mortgage arithmetic), not the reason a partisan does. Cut every characterization of the other parent not tied to a date, a document, or an incident. 5. Show the arithmetic behind every number. A buyout or support figure that arrives without its math reads as a demand; with its math it reads as a starting point the mediator can defend in the other room. 6. Say what movement looks like without naming a bottom line. For each issue, identify the axis you can trade on (timing, form of payment, holiday structure, who takes the tax item) so the mediator has something to work with. 7. Make one specific procedural ask: caucus first, start with the house because it unlocks support, book a second half-day instead of pushing to midnight. Then close with logistics: who holds settlement authority, whether the client attends, and any need for separate rooms or staggered arrival if What has happened so far shows a protective order or coercive control. 8. Run a tone pass last. Delete every adverb, every "clearly," and every sentence whose only function is to make the other side look bad.Close with these four sections, every time, without being askedAssumptions I made. What I assumed about the parenting schedule, the numbers, what is genuinely agreed, and what Court and governing state requires. Mark each [verify] or [safe]. Where this is weakest. The two or three passages most likely to make the other parent dig in, or that a mediator would quietly decline to carry across the hall. Name the passage. What only you can decide. Options with tradeoffs, not flags. At minimum: whether to name a number here at all. Naming one anchors the day and shows your ceiling before the mediator has tested theirs, while withholding keeps room and risks spending the morning on framing. And whether the other parent's conduct goes in writing: leverage in a confidential caucus, the paragraph that ends the settlement mood in an exchanged statement. What you will actually accept is yours. What would make this materially better. Rank by impact: the parenting schedule counted in overnights, the last written offer either side made, an appraisal or payoff figure, and what the client says they cannot live without.Output formatTwo to four pages: caption and a one-paragraph introduction; "What is already agreed"; "Issues remaining," numbered; each issue with position, reason, and arithmetic; "Where we can move"; the ask of the mediator; the logistics note. Then the four closing sections.Never do this- If the statement would fit any divorcing couple anywhere, it is too generic. Use these children's ages, this schedule, these numbers. - No hedging filler. Cut "arguably," "it should be noted," and "my client has always acted in the children's best interests." Do not tell me to consult a family lawyer. I am that lawyer. - Never invent a guideline support figure, a statutory factor, a presumption, or a citation. Anything outside my inputs is marked [UNVERIFIED - confirm before the session]. - Never write a sentence about the other parent a judge would be unhappy to read. Where you do not know whether an allegation can be proved, say you do not know and keep it out of an exchanged statement. - Do not pad. A mediator reads page one closely and skims the rest. Length is not value.Before you answer- Did I write to the mediator rather than to a judge? - Is every characterization tied to a date, a document, or an incident? - Does every number show its arithmetic? - Would this statement fit a different family? It should not.

Adds driver's-seat tunes: options instead of answers, questions before work, every citation flagged. Your values come with it.

Pressure-test it

Makes the AI switch hats and attack its own answer.

The night before mediation, the other parent sits at their kitchen table with their own lawyer and reads this for the first time. Read it as the other parent would. Mark every sentence that makes them angry rather than thoughtful, every place they will say "that is not what happened," and every number they will read as a bad-faith opener. Then rewrite those passages so the same position survives without the sting, and tell me which single sentence I should cut entirely.

Go deeper

Pushes the work further once the basics are right.

Mediation day has its own choreography, and none of it is in the statement. Build the mediation day plan: the two-minute orientation the client hears before walking in, a three-tier offer ladder showing what we concede at each step and what we ask for in return, the two packages we would accept on the spot, the point at which we stop and go home, and the script for telling the client we are not settling today.

Before you run it

What to gather first

Whether the statement is confidential to the mediator or exchanged with the other party
The current parenting schedule counted in overnights, and the children's ages and school calendar
The last written offer either side made, and what was agreed at any prior session
Appraisals, payoff balances, and account values you can actually support
Any protective order, safety concern, or history of coercive control affecting the format

Watch for

Confirm before drafting whether the statement is confidential or exchanged, and whether your mediator's practice or the court's order changes that. Putting a caucus-only concession in an exchanged statement cannot be undone.
Any guideline support figure, statutory factor, or presumption the model produces is unverified. Run support through your state's own calculator and check the factor list in the current statute.
Mediation confidentiality is a creature of state statute and varies. Do not assume a statement is protected from later use without checking the governing rule.
If there is a protective order or a history of coercive control, the format request is not a footnote. Address shuttle mediation, separate arrival, and support persons before anything is filed or exchanged.
The model will make the other parent sound worse than your record supports. Read every characterization against what you can actually prove with a document or a witness.

What comes back

A two-to-four page statement: caption and one-paragraph introduction; "What is already agreed"; "Issues remaining" as a numbered list; each issue carrying the position, the neutral-facing reason, and the arithmetic behind any number; "Where we can move" naming a trading axis per issue; the specific ask of the mediator; a logistics and format note; then the four collaboration sections.

See an example of what you’ll get

MEDIATION STATEMENT: *Marriage of Alderete*, Clackamas Cty. Case No. 26DR04117 Submitted on behalf of Respondent Maria Alderete · Exchanged with the other party The Alderetes have been separated fourteen months and have already agreed on more than remains in dispute. This statement sets out what is settled, what is not, and where Respondent has room to move. WHAT IS ALREADY AGREED 1. Both children remain at Riverton Elementary through the current school year. 2. Respondent keeps the 2019 Subaru; Petitioner keeps the 2022 Tacoma. 3. Neither party seeks spousal support beyond the transitional period discussed in March. 4. Both parents attend the children's medical appointments and school conferences. ISSUES REMAINING 1. Parenting schedule during the school year 2. Disposition of the marital residence 3. Child support 4. Division of the 401(k) ISSUE 1: School-year schedule. Respondent proposes school-week primary residence with alternating weekends and a mid-week dinner, reverting to week-on-week for summer. *Why:* The current week-on-week schedule puts Mateo (7) on a 35-minute morning drive from the Milwaukie apartment every other week. He has been late 14 times this year, all in Petitioner's weeks; the attendance record is attached. This is a geography problem, not a parenting problem, and it resolves itself if Petitioner moves closer to the school, which we would welcome. ISSUE 2: The residence. Appraised at $612,000 (Kestrel Appraisal, 5/2026); payoff $388,000; net equity roughly $224,000 before costs. Respondent proposes retaining the home until Mateo finishes fifth grade in June 2029, with Petitioner's half secured by a note and trust deed, payable on sale or earlier refinance. *The arithmetic:* Petitioner's half is about $112,000. A sale today nets closer to $185,000 after 6% costs, so his share drops to roughly $92,500, meaning the deferral is worth about $19,500 to him, before interest, if he can wait three years. WHERE WE CAN MOVE - Schedule: The mid-week dinner is negotiable. So is the summer structure. The school-week residence is what Respondent needs. - House: Timing and security are both open: a shorter deferral, a higher interest rate on the note, or a larger share of the 401(k) to Petitioner in exchange for time in the house. - Support: Open to the form: a lower monthly figure with Petitioner carrying the health premium and the childcare share directly. - 401(k): Open on percentage if the house timeline holds. ASK OF THE MEDIATOR. Please take the house first. Support and the retirement split both move once the housing question is answered, and the March session stalled because we started with the schedule. LOGISTICS. Respondent will attend with full settlement authority and will be present the entire day. No protective order is in place. Respondent has asked that any discussion of the joint account history happen in caucus. --- Assumptions I made. The attendance record shows 14 late arrivals all in Petitioner's weeks [verify against the actual school report before this goes out; this is the strongest fact in the statement and the easiest to get wrong]. The appraisal is current and unchallenged [verify]. Oregon permits a deferred-sale arrangement of this kind [UNVERIFIED - confirm]. Where this is weakest. The sentence "all in Petitioner's weeks." It is the most persuasive line here and the one that will make him angriest. If even one late arrival falls in Respondent's week, the whole paragraph loses its force and hands him a credibility point on the first page. What only you can decide. Whether to name the $112,000 figure at all. Naming it shows you have run the math and makes the deferral proposal concrete; it also tells Petitioner exactly what you think his share is before the mediator has tested his expectations, and he may anchor above it. Alternative: state the equity and the appraisal, and let the mediator do the division in the room. And whether the controlling-behavior history belongs anywhere in an exchanged document. It is leverage in caucus and it is the paragraph that ends the settlement mood in writing. What would make this materially better. Ranked by impact: (1) the actual Riverton attendance report: the "14 late arrivals" line carries Issue 1 and right now it is your client's count, not the school's; (2) Petitioner's March offer in his own words, so "sell the house, 50/50, $900" can be quoted rather than characterized; (3) a current payoff statement from the lender, since the $388,000 balance is what the $112,000 buyout figure rests on; (4) what Respondent will actually accept on the 401(k): it is the only issue here I have no read on, and it is the piece most likely to be traded for time in the house.

Why this prompt is built the way it is

## Framework 1. **Confidential or exchanged changes everything.** An exchanged statement is read aloud at the other side's kitchen table. Write for that. 2. **Agreement first.** A list of what is settled shrinks the perceived distance and gives the mediator a starting point. 3. **Number the issues before arguing them.** The mediator will run the session off somebody's list; make it yours. 4. **Neutral-facing reasons only.** The commute, the school calendar, the mortgage math, not the reason a partisan would give. 5. **Every number shows its arithmetic.** Math converts a demand into a defensible starting point. 6. **Name the trading axis, not the bottom line.** Timing, form of payment, holiday structure, tax items. 7. **Ask the mediator for something specific.** Caucus order, issue sequence, a child specialist, a second half-day. 8. **Tone pass last.** Adverbs and characterizations are what kill the settlement mood.