5. Set the tone with your opening statement
If your client wishes to make an opening statement, this would be the ideal opportunity to set the tone and get their position and view of facts and circumstances across - particularly if the dispute has affected them personally. However, be mindful that hostile and overly passionate opening statements can backfire by resulting in parties becoming entrenched in their own positions too early in the day.
I consider that opening statements that are realistic, unbiased and succinct are more conducive to a successful mediation.