The odds of reaching agreement may not be fully bankable, but certain terms that you will deem necessary are.
Come to mediation with a document in hand, and/or on a memory stick or thumb drive, that can either serve as a Settlement Agreement, itself, or provide terms which can easily be attached or incorporated into something drafted at the table.
Leave blank lines, or even a blank page, to insert particulars. Include terms that are yet to be determined as applicable, such as Older Worker Benefit Protection Act language. It’s easy enough to strike them. Have parties initial next to handwritten insertions or modifications.
It doesn’t have to be pretty; just legible.
It’s not a bad idea to bring a couple of copies so that everyone can read along at the same time. In the end, you’ll have originals for each party to sign and keep, too.
This simple preparation is guaranteed to offer the chance of saving yourself the worry (or actuality) of things unraveling between the end of a session and the exchange of a formal agreement, and eliminate the delay of finality.
