Opening Statement

I will be acting as the counsel for Rohan/Neha in this session, I would like to
clarify at the very outset that all decision-making power lies in the hand of my
client and am present here in a mere advising capacity.
To begin with I would like to take the opportunity to thank the other party to
agree for this mediation session
It’s good to see we can set outside all the resentments with each other and sit
together to amicably resolve this dispute.
I would like to say that we do not wish to dwell upon the complex legalities of
this issue, my client hopes to resolve this matter amongst ourselves and
without taking it to court.
Now moving forward, I would like to thank the mediators for briefing our
clients with the rules and procedure of this session.

I am sure they are feeling very comfortable with the whole mediation process
with the way you explained the whole thing.
Now coming to the reason that we have gathered here, the issue between my
client and Mrs Neha is regarding the the will left behind by Mr Rajeev kapoor
which gives my client the entire estate which is a 3 storey house in Jasola, New
Delhi, several paintings and entire investment portfolio
There was a lot of miscommunication between us, but we would like to keep
aside all of this and discuss about what can be done now because its apparent
that both of us have faced heavy losses.
MOVING FURTHER
The things that my client wishes to discuss in this session are -
First being- is a way for us to negotiate which is beneficial for both of us and to
best of our interests
Second being- discussing on what will be a fair distribution of the estate and
properties and what will justify the right of both the parties
We are ready to talk through all of these issues and
I would also like to request the opposing party to negotiate with us in good
faith keeping in mind the very spirit of a mediation session
Hopefully by the end of this session we can reach a common ground and the
issue at hand is resolved.,
That’s all from our side
Thank you.