2536 Columbine Circle
Lafayette, CO 80026
Robin N. Amadei, Director
phone: 303-604-1960
fax: 303-604-6278
Email: ramadei@aol.com
Common Ground Mediation and Coaching, LLC
Helping People Reach Common Ground




People involved in disputes can choose from a variety of alternatives to litigation, ranging from informal negotiation to more formal arbitration.  This article will focus on mediation, illustrating that this form of ADR encompasses a broad range of styles, techniques and approaches that depend on the mediator's outlook, background, training and experience as well as the type of case.  Generally mediation is defined as "an intervention in dispute negotiations by a trained, neutral third party with the purpose of assisting the parties to reach their own solution."[1]  Clearly, this broad definition could apply to numerous different types of intervention, potentially creating confusion among clients, lawyers, the judiciary and mediators themselves.  The objectives of this article are to help clarify the many faces of mediation as well as to open up a dialogue on this important issue.

The Mediation Process Spectrum

One way to view the different approaches to mediation is to look at a spectrum of style possibilities. 


Process-oriented Approach                                     Substance-oriented Approach
(Formal or Judicial Settlement Conference)

Process-Oriented Mediation

On one end of the spectrum is the "process-oriented" approach.  This style of mediation presumes that the parties hold the solution to their dispute and can, with process assistance, arrive at a solution with which they can all live.[2]  While the mediator helps the parties to clarify, organize and understand the factual and legal issues involved in the case, the mediator does not recommend a solution based upon his or her analysis of the case.  In this approach, one of the mediator's jobs is to encourage the parties to expand their discussion beyond the narrow range of legal issues in dispute so that they can craft a more creative, flexible and appropriate solution than that which might result if the case were litigated. 

Stylistically the mediator is the facilitator of a process, as opposed to an authority figure providing substantive advice and pressure to settle.  The process-oriented mediator's focus is towards empowering the parties to define and resolve the dispute themselves.  S/he creates a comfortable environment where information sharing can take place, thus enhancing each party's understanding of the other party's, as well as his/her own, needs and interests.  Mediators employ techniques such as active listening (focusing on what is important to each party), reflecting (validating and checking for understanding) and reframing (neutralizing toxic language) to help parties get past anger, disappointment and their own egos and to see a more complete picture. 

Once parties can understand and receive validation of their emotional needs, they are prepared to rationally focus on issues and generate and evaluate settlement options[3].  Depending on the case, the mediator might ask questions to help clarify the parties' thinking on issues, to determine if additional information is needed to make a good decision, and to test the parties' perceptions about their alternatives to a negotiated settlement.  If additional information is necessary before good decisions can be made, the mediator can help the parties prepare a list of research items or things to consider before entering into an agreement on a given issue.  Also, mediators can provide referrals to other professionals if requested by the parties.

This style of mediation encourages the use of an interest-based bargaining approach where parties are asked to explore the interests (needs) underlying the positions they are taking[4].  Then, parties are invited, usually in joint session, to generate options that meet their interests.  Following this step, the parties are asked to evaluate the options generated in light of their interests and other criteria that the parties may have developed or that may be mandated by law.  Presumably, through this evaluation process, the most acceptable option or options are agreed to and written up into an agreement.  The objective of a process-oriented mediation is to move participants into a win/win mind set where mutual gains can be obtained[5]

Substance-Oriented Mediation

At the other end of the spectrum is the substance-oriented approach.  An approach to mediation at this end of the spectrum is virtually indistinguishable from a traditional settlement conference.[6]   This model is often used by former judges who now mediate. In a substance-oriented mediation, the mediator evaluates the case based upon his or her experience and offers substantive recommendations on how the case should be resolved.   Usually this recommendation is based on how the mediator believes the case would turn out if it went to trial.  Usually, the recommendation is made in the context of a judicial analysis, limiting the issues presented by the parties in mediation to those that would be considered by the legal system.  Assuming that the parties respect the mediator and his/her judgment, they will weigh this recommendation and negotiate settlement accordingly. 

This approach has a very different stylistic feel to it than the process-oriented model.  Because  the mediator is often an authority figure (e.g., a former judge), the parties tend to appeal to the mediator instead of each other in presenting their perspectives.  Therefore, the parties are likely to present their cases in an adversarial manner to increase the chances that the mediator's recommendation is favorable to their particular side.

Once a valuation of the case is made by the mediator, s/he exerts influence to move the parties closer together in their positions to hone in on a settlement.  Much of this work is done in caucus, or individual sessions, using shuttle diplomacy techniques.  The mediator will use his/her power and influence to move parties off of their positions through reality testing and creating doubt.  The mediator frequently ferries offers back and forth until, if the case does settle, some sort of compromise is reached. 

Analysis of the Spectrum

Mediators fall on many points of the spectrum, based upon their own personal style and the cases that they handle.  Although mediators often alter their styles based upon the demands of the cases before them, mediators may have a basic orientation.  Many family mediators have a more process-oriented approach, for example.  On the other hand, ex-judges mediating civil cases often use more of a substance-oriented approach. 

The authors think that the process-oriented mediation model is under-utilized by a vast majority of mediators for numerous reasons.  The process-oriented model can be more time-consuming, more open-ended and less directed, which could be troubling for ex-judges and other lawyers used to the traditional system of dispute resolution. Former judges and attorneys are used to retaining control over the outcome, giving advice, advocating for positions and having their suggestions heeded.  Also, the process-oriented model can be a more difficult and energy-intensive model to use[7].  Assuming substantive expertise, evaluating a case is fairly straightforward: opinions are offered and strengths and weaknesses are pointed out.  Truly listening to the parties, understanding their psychological motivations and asking questions so that the parties themselves can hear each other and craft an appropriate solution can be challenging.

The parties might end up settling the dispute regardless of whether a process-oriented or substance-oriented approach is used.  So why do we recommend using a process approach in most situations, at least initially?  One reason is that at the conclusion of a substance-oriented mediation, the parties may not completely embrace the solution because it is derived by an authority figure instead of themselves.  They may not have had the opportunity to take responsibility for their end of the conflict, nor enjoy the psychological satisfaction of working through and resolving their dispute.  Further, the parties may feel that they are intimidated into signing the agreement by an authority figure, further minimizing their commitment to the result.  In a substance-oriented mediation, the process is often more adversarial in nature and does not enhance understanding among the parties.  Therefore, relationships are not likely to be improved.

Additionally, the results obtained in mediation are less likely to be interest-based and truly collaborative in a substance-oriented mediation.  According to Moore, five approaches can be taken when parties are in conflict: competition, avoidance, accommodation, negotiated compromise and interest-based negotiation[8].  In a substance-oriented mediation, the parties would have a tendency to either compete, negotiate a compromise or accommodate.  Clearly, none of these approaches provide optimal satisfaction for both parties because underlying interests are not addressed.  Either one party is happy with the result while the other party is miserable, or at best, both parties are lukewarm about the result. 

In a process-oriented mediation, the parties are more likely to achieve an interest-based solution that optimizes everyone's satisfaction because parties are encouraged to develop a creative solution that neither one of them would have come up with on his/her own. 

Furthermore, a successful process-oriented mediation provides the parties with an opportunity to: describe the situation from their perspective, understand and be understood, create and evaluate options using the criteria that they have developed and enter into an agreement that makes sense for them.  And, participants have the opportunity to gain self-respect and recognition for each other through the process of identifying their own interests as well as listening to and understanding those of the other party[9]

Parties who create their own solutions are more likely to be satisfied with the process and the outcome; ultimately they will also be more committed to upholding the agreement.  Process-oriented mediation also provides the opportunity to repair damaged relationships, whether in the workplace, business, neighborhood, schools, community or family.

Although the authors are oriented towards process-oriented mediation for most cases, there are those instances where a substance-oriented mediation would be preferable.  Attorneys should  fully understand the different approaches that fall within the broad term "mediation."  Then,  attorneys should evaluate the case at hand to determine which style or approach might be most useful given the specific attributes of the case[10]

A more substance-oriented mediation might be called for when:

!  Parties are far along the litigation road and are firmly entrenched in adversarial positions
! There is a discrete and defined resource in dispute (usually money)
! There is no ongoing relationship between the parties
! There is a major power imbalance
! There are no common or complementary interests (needs)
! Trust between parties is impossible 

A process-oriented mediation style may be more appropriate when:

! Parties have the capacity and the desire to work through the issues and craft their own solutions
! The dispute involves past or ongoing relationships (employment, business,             commercial, neighborhood, family)
! Future relationships are important
! Parties are willing to share information and work towards a settlement in good faith
! There are common or complementary interests (needs)
! There is a relative balance of power
! There is a potential for trade-offs on related issues
! The parties are emotionally charged and could move forward if such emotions could be diffused. 

Case Examples

The above analysis suggests that certain factors in a case may make a substance or process approach more appropriate given specific case attributes.  Following are case examples that analyze factors that might indicate either a substance or process orientation.  Please note, however, that this analysis is not meant to be used as a formula.  Every case is unique.  Indeed, a versatile and flexible mediator is likely to custom-design his/her approach to accommodate the attributes of the case and the parties' needs and interests.   Also, during the mediation itself, developments may indicate that a change in approach would best serve the parties.  As stated in the Colorado Bar Association's Manual on Dispute Resolution:

It is important to know that the difference between mediation and settlement conferences is basically one of style.  Mediation uses facilitative or interest-based techniques, and settlement conferences use directive and reality-testing techniques...[B]oth techniques may be used in the same session by the same neutral.  The choice of style depends on the issues and needs of the parties[11].

With the above caveats in mind, we suggest that certain types of cases do lend themselves more readily to either a process-oriented or substance-oriented approach.

1.  Business mediations where the parties will potentially maintain a continuing relationship.

One of the strongest indicators for using a process-oriented approach is an anticipated  continuing relationship among the parties.  In cases where the parties are strongly motivated to work through issues, they can benefit from a mediation model that enables them to express their needs and interests, explore options and negotiate a resolution.   Moreover, when  business people are involved, they typically have the acumen to generate their own options and decide what is workable from their perspective.  When parties will have an ongoing relationship, they can often craft creative solutions that will address their future needs and circumstances.  Additionally the process itself can help parties develop communication and problem-solving skills that they can use after the mediation is completed.

For example, in a product supplier/customer dispute mediated by one of the authors, a customer refused to pay for the goods that he had ordered, claiming that they were of inferior quality.  If a substance-oriented mediation approach was used, the case might have been settled with an agreement on the amount of money that the customer would pay to the supplier.  Since a process-oriented approach was used, however, the parties dealt with their relationship issues in addition to the presenting problem.  The parties ended up working out a creative solution that included a dollar amount for the existing order, and the customer received future products  at a discounted price.  Through the use of a process-oriented approach, the business relationship was maintained and both parties felt good about the result since each person got something of value.

2.  Property damage cases where two insurance companies are negotiating liability amounts.

In situations where parties have no continuing relationship, no common interests and only need to distribute money, a substance-oriented approach might be more appropriate.  In a zero-sum situation, one party's loss is another party's gain.  When a situation of this type is present, some sort of objective criteria is advisable to break a deadlock[12].  The mediator can serve as the voice of objectivity in this type of situation.  S/he can assess the case and, based upon his/her background and experience, recommend a dollar amount for settlement.  If one party has a totally unrealistic assessment of a claim, the mediator might point out to the party or attorney the likely result if the case went to trial.  If the parties respect the mediator and are assisted in more objectively evaluating the strengths and weaknesses of the case, an appropriate settlement can be attained.

3.  Real estate disputes where the buyer is disappointed with the condition of the home and wants compensation from the seller.  The seller is denying any liability.

At first blush, one might think that since this dispute is about money and the parties do not anticipate a continuing relationship, a substance-oriented model would be more appropriate.  On the other hand, this type of case probably has an emotional component to it as well.  The buyer is probably experiencing disappointment about the condition of the home and is angry at the seller.  This anger, more than actual financial damage, could be providing the energy and motivation to litigate the issue.  If the buyer were given the opportunity to vent his/her feelings, to be heard by the seller and perhaps to receive an apology, the parties might be free to move towards a settlement.  The settlement agreement could be financial in nature, could provide that the seller fix the offending problem, or could be based on some other sort of compensation. 

In a case mediated by one of the authors, a buyer was suing a seller for water damages to a room discovered after closing.  After the parties had the opportunity to state their perspectives and to be acknowledged by each other, they began developing options to settle the case.  During the discussion, the seller happened to mention that his brother was in the landscaping business.  One thing led to another and the parties agreed that the seller would provide bushes and trees to the buyer at cost to settle the case.   A substance-oriented approach to this mediation might never have uncovered this creative option.

4.  An environmental mediation where the parties specifically desire substantive expertise due to the specific nature of the case.

In certain types of disputes, the parties often hire a mediator to manage the process as well as to offer substantive expertise.  This orientation may be requested if the case is technical in nature or if unrepresented interests may be affected by the decisions made in the mediation.  This role could be especially critical where issues decided in mediation could have precedential effect.[13] 

For example, parties selecting an environmental mediator for a hazardous waste disposal mediation may lean towards a neutral who has knowledge and expertise in this substantive area and who could be both a process expert and could offer substantive recommendations.  The parties may realize that because unrepresented parties could be affected by the decisions to be made, a mediator with a more global orientation might be able to offer an important perspective to the issue.  At the same time, the parties will want a process expert to help them raise and frame issues, generate and evaluate options and negotiate an agreement on the important decisions with which they are charged. 

5.  Recovery of money secured by a promissory note owed to plaintiff due to the failure of the defendant's business.

In a case of this type mediated by one of the authors, the parties to the dispute were substantially enmeshed in the litigation process, they were extremely adversarial and they could not imagine working together again.  Further, a fixed amount was in dispute and trust was non-existent.  Therefore, indicia pointed towards conducting a substance-oriented mediation. 

On the other hand, the parties were emotionally charged to a degree that they could not rationally approach the issue at hand.  The money represented a lot more than its cash value.  The plaintiff felt that he had been lied to and that the defendant had mismanaged the business to such an extent that it was no longer operational.  Hence, the plaintiff was out a lot of money.  The defendant felt angry and upset by the fact that the business did not thrive.  He  blamed the plaintiff for not recognizing all the work that he had done for him free of charge during the time that the business was in operation.  Given these factors, the mediator used a process-oriented approach.

In mediation the parties had the opportunity to present their perspectives.  Although the relationship could not be repaired, the parties did obtain an increased understanding of each others' situations.  This enabled them to narrow the range of their offers from thousands of dollars apart to a few hundred dollars.  Then, when a true impasse seemed imminent, the parties decided to donate the amount differential to two charities of their choosing.  This case, which seemed intractable four hours earlier resolved amiably through the efforts of the parties.  The mediator offered no valuation of the case, but instead guided the process to its successful conclusion.

6.  Sexual discrimination and other types of employment cases.

Workplace disputes are very amenable to a process-oriented mediation approach.  Either the aggrieved worker remains at the company and wants to maintain good relationships with his/her employer, or the worker wants to leave the company with his/her co-workers thinking highly of him/her.  Whether or not the employee leaves the company, the employer also wants to work through the dispute amiably.  Employers generally want to engage in a fair process for dealing with employment disputes and wish to avoid litigation.  Moreover, employee disputes can affect worker morale company-wide.  Engaging in a mediation process that results in mutual satisfaction can turn a detrimental situation into a positive result.  Even if the dispute appears to be primarily about money, the related issues can permit trade-offs to occur.   

Employment  cases can be very emotional in nature because self esteem, job satisfaction and personal relationships are often involved.   For these reasons, the aggrieved party should be given the opportunity to be able to tell his/her story.  Because workplace disputes typically contain many common interests, especially if the employee is to remain at the company, these cases are very resolvable. 

In a sexual discrimination case mediated by one of the authors, the opportunity to be heard and understood as well as the ability to influence a change in company policy was the primary motivation for the aggrieved worker to go to mediation.  The employee felt that although she  potentially could have recovered some money from the employer if she had sued, staying with the company and making things better for herself and other women who worked there was more important.  A process-oriented mediation allowed for this result.

7.  Divorce and child custody cases

Most of these types of cases benefit from an approach that falls closer to the process-oriented end of the spectrum.  The parties, by definition, will have had an intimate relationship that, for whatever reason, transmuted from love to negativity.  The resolution of the issues raised by the change in the relationship will deeply affect how the parties go forward with their lives.  When children are involved, the parenting relationship will continue after the divorce is final.  A process-oriented approach to mediation allows the parties to identify their needs and interests and to consider those of their soon-to-be ex-spouse.  The opportunity to voice hurt and frustration and to be heard and validated often allows parties to move ahead with  developing a business-like approach to resolving property and parenting issues.  Although divorcing parties may not be at their best, they can usually make better decisions for themselves and their children than an outsider can[14].

In some instances, one or both of the divorcing parents are so entrenched in their own conflict that the fight becomes more important than the best interests of the children.  Sometimes the parties can not see their own best interest because they are blinded by rage.  By using a process-oriented approach, the mediator can sometimes help the parties refocus their attention on the issues.  Other times, a more substance-oriented approach might be more effective.  This may be especially appropriate when issues regarding the children are being discussed and the parents are not able, or willing, to separate the conflict from the best interests of their children.  In extreme cases, a hybrid process of mediation/arbitration can be used[15].

8.  Community and Neighborhood Disputes.

These cases often involve ongoing relationships and heartfelt interests and are well-suited to a process-oriented approach.  In neighborhood disputes emotions can run high. Often, miscommunication and misunderstandings have exacerbated the disputes.  By providing the opportunity for parties to speak, to be understood and to understand, everyone can move beyond an emotional response into a cooperative problem-solving mode.

In a recent neighborhood dispute mediated by one of the authors, neighbors were upset by the noise generated by the loudspeaker system of a local car dealership.  Zoning and noise ordinances did not prohibit the loudspeaker system.  After venting frustrations and anger at the noise problems, the neighbor representatives were able to understand the dealership's needs for a loudspeaker system and the lengths to which the business had already gone to accommodate the neighbors.  Once they were convinced that the dealership did indeed care about the neighborhood, the neighborhood representatives could offer suggestions and solutions short of closing down the entire loudspeaker system.   

Lawyers' Roles in Mediation

Lawyers are integrally involved in the mediation process regardless of the mediation approach selected.  First, lawyers should discuss with their clients what type of mediation approach might be appropriate given the attributes of the case and the desires of the parties.  The parties should clearly understand and consent to the style of mediation to be employed.   Lawyers should also contact a few mediators to get a sense for whether the mediator's style is consistent with the needs of the client and case.  Most mediators are happy to discuss their backgrounds, styles and approaches.  Then, the parties and/or lawyers representing each side need to select a mutually acceptable mediator.

Once a mediator is selected, the mediator and attorneys for each side should discuss case preparation.  A mediator may request the attorneys to prepare a confidential statement of facts and law to assist him/her in case preparation.   Also, each attorney should have a pre-mediation meeting with his or her client to discuss in greater detail the mediation style and process to be undertaken, as well as the client's legal rights and potential liabilities given the circumstances of the case, ultimate objectives of the client, underlying interests that the client needs to have satisfied and settlement range.  Also, counsel and client should discuss the strengths and weaknesses of the opposing side's case as well as analyze what the other side's underlying interests and concerns might be.

Whether attorneys should attend the mediation session or not is situation-specific.  In many civil cases and other substance-oriented mediations, the attorneys do attend the mediation sessions.  This is especially true for cases where the stakes are high or where legal issues need to be articulated.  Additionally, if one party's attorney plans to attend the session, the other party's attorney should probably attend as well to maintain a balance of power.

If the lawyers attend the mediation, their involvement in the process is defined by the style of mediation employed and the attributes of the individuals present.  A substance-oriented mediation model may have more of a legal focus and hence tend to involve the attorneys in a more active role.  A process-oriented approach relies more heavily on the involvement of the parties themselves, although the lawyers participate in setting forth the legal issues and in helping to generate options. 

In situations where the parties feel comfortable in articulating their concerns and have been adequately coached by their attorneys, the clients may attend mediation without counsel.  In this situation, each attorney should be available by phone if questions come up.  Also, between mediation sessions, each attorney should talk with his/her client and perhaps the mediator to discuss progress being made and new issues that arise.

Once an agreement is reached in mediation, either the mediator or one of the attorneys prepares a written document.  The agreement is reviewed by all parties and their attorneys and, if acceptable to everyone concerned, is then signed.

Questions to Ask Mediators to Determine Style and Experience

1)  What is the mediator's specific training and background?

2)  What is the mediator's experience in the substantive area of the dispute?

3)  Does the mediator satisfy the Colorado Bar Association/ADR Committee, Colorado Council of Mediators and Mediation Organizations' Recommended Guidelines for Mediator Education and Training?[16]

4)  What are the costs for the process, what services are included in the fees quoted and how will such costs be allocated to the parties?

5)  What style of mediation does the mediator use?  Will the mediator focus on the parties' needs and interests and empower them to reach a solution (process-oriented), or will the mediator provide substantive recommendations to bring about a settlement (substance-oriented)?  Is the mediator comfortable with both approaches?  How flexible can he or she be?

6)  How will the mediator ensure that the parties' rights of self-determination, confidentiality,             and neutral treatment are maintained?

7)  Do any conflicts of interest or appearances of conflict exist between the parties to the mediation and/or their attorneys and the potential mediator?

8)  Does the mediator subscribe to a code of ethics?

9)  Is the mediator's personal style and tone comfortable for the parties?

10)  Does the mediator have a list of references to share?


The mediation process encompasses a broad range of stylistic approaches that can be defined on a spectrum.  At one end of the spectrum is a process-oriented approach, which presumes that parties hold the solution to their dispute and can, with process assistance, arrive at a solution that will be more appropriate than one imposed by an outsider.  At the other end of the spectrum is the substance-oriented approach, which is virtually indistinguishable from a traditional settlement conference.  This style presumes that the mediator will evaluate the case and offer substantive recommendations on how the case should be resolved.  Mediators fall at  many different points on the spectrum, based on their own personal styles and the cases they handle.

The authors think that the process-oriented mediation model results in a greater feeling of client satisfaction, can repair frayed relationships and could lead to more creative solutions in many cases.  Although a process approach can be more time consuming, more open-ended and less directed, it is well worth the effort for most cases given the potential advantages.  For some cases, however, a substance-oriented model is more appropriate.  Mediators should be willing to help attorneys and their clients evaluate their situation and discuss whether mediation is appropriate and which mediation style or approach may be most useful given the particulars of the situation.  Mediators should be willing to articulate what styles they are comfortable with employing and how they will approach a particular case if chosen as mediator. 

Lawyers are integrally involved in the mediation process, regardless of the approach selected.  They often play a key role in mediator selection, as well as in case preparation and process participation.  Of course, if an attorney's client is satisfied with the resolution, the attorney benefits by being the person who provided guidance, advice and representation in the mediation context. 


8 Robin N. Amadei, Common Ground Mediation and Coaching, LLC,  303-604-1960 and Lillian S. Lehrburger, The Professional Mediation Alternative, Inc., (303) 837-1234.  1996.  All rights reserved.


[1]CRS 13-22-301(2.4)

     [2]Moore, Christopher. The Mediation Process. San Francisco: Jossey-Bass Publishers, 1986. 40.

     [3]CDR Associates, The Mediation Process Training Manual.  Boulder, CO. 1990.

     [4]Fisher, Roger and Ury, William. Getting to Yes. New York: Viking Penguin Inc., 1981.

     [5]Hall, Lavinia. Negotiation: Strategies for Mutual Gain. Newbury Park, CA: Sage Publications Inc., 1993.

     [6]The Alternative Dispute Resolution Committee of the Colorado Bar Association.  Manual on Alternative Dispute Resolution. Denver, CO: Colorado Bar Association (1992): 2,7.

     [7]Phillips, Barbara A.  Finding Common Ground, A Field Guide to Mediation. Halfway, OR, 1994: 117-119.

     [8]Moore, op. cit., 68.

       [9]In fact, some process-oriented mediators go so far as to suggest that enhancing the empowerment and recognition of parties should be the ultimate goal for mediators rather than facilitating agreements.  See: Baruch Bush, Robert and Folger, Joseph. The Promise of Mediation: Responding to Conflict Through Empowerment and Recognition.  San Francisco, CA: Jossey-Bass Publishers, 1994.  The authors of this article would not go this far, but have found that enhanced communication skills and self and mutual respect are often by-products of a process-oriented approach.

     [10]Moore, op. cit., 61-77.

     [11]Colorado Bar, op. cit., 7

     [12]Fisher and Ury, op. cit., 84-98.

     [13]Suskind, L. "Environmental Mediation and the Accountability Problem," Vermont Law Review, 1981, 6 (1), 1-47.

     [14]Friedman, Gary J.  A Guide to Divorce Mediation. New York: Workman Publishing Co., Inc, 1993.

     [15]Amadei, Robin N.  "Mediation/Arbitration: An ADR Tool," The Colorado Lawyer, 24(3): 553-555.

     [16]These guidelines may be obtained by calling the Colorado Council of Mediators and Mediation Organizations at (303) 322-9275.

Helping People Reach Common Ground