Questions in Caucus - Information Gathering by a Mediator

Is there anything that I don’t know that is important to you but you were not comfortable
sharing in the joint session?

How do you feel about this conflict on a whole... and how does it feel right now? How do
you feel about the other side right now?

What do you really want out of this session. How would you ideally like it to end?

You say going to court is the other alternative. What are your expectations of this trial? How
long do such cases take to reach closure? How are your other alternatives weighing up1?

What do you think is their strong point in this case? What do you think are their alternatives
if this Mediation fails today?

What would you like to change about whatever has happened so far? Are you comfortable
with the process or do you prefer changes?

What would it feel like to be in their shoes? Are you able to gauge their perspective so far?
Why do you feel they are not opening up on this point?

This point that kept coming up, do you think you two share a common opinion on this? Do
you believe this could be the common ground from where we move forward?

What do you think it will take for them to settle this case? What do you believe are their
needs in this particular case and at this stage of conflict?

Can I possibly do something more to help you proceed towards settlement?

If they move to point X, would you be moving to point Y. If not, what else could you do to
appreciate they moving from their position to point X?

Have you considered reaching out to them with an offer? For now, you have not anchored
on anything and no negotiations have begun on this point...

- Do you think the conflict originated much before the obvious source that we keep referring
to? Who else do you think is involved, affected or influencing this situation?

Compiled by Jonathan Rodrigues, The PACT Mediation Workshops _ 2019