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Setting Deadlines and Time Limits

July 28, 2014

I came into a mediation the other day and announced that my wife and I had concert tickets for that evening at the Hollywood Bowl; therefore I needed to leave by 3PM, 4 at the latest, so I could meet my wife at home to go together to the concert.

(Of course I had my ticket with me in case the mediation went longer and my wife and I had to meet at our seats, but I set a deadline to move the case along.  And I didn’t really want to miss the concert either.)

By 3:30 PM, we had reached an agreement; by 4:00 PM the agreement had been documented and signed.

I met my wife in time and the concert was wonderful.

Sometimes, an attorney will start off a morning mediation with an announcement that he or she has a court hearing or deposition scheduled for the afternoon, and sometimes that too will help the mediation fit the time schedule.

Deadlines and time limits, when announced up front, sometimes avoid the mediation dragging on and on without much progress.

On the other hand, I remember stating at the outset of a mediation that a friend’s father’s funeral was set for 4PM that day and I wanted to be able to go. But I never made it to the funeral. The vigorous pace and continuing intensity of the negotiation required that I stay to manage the impending settlement and, fortunately, there was a satisfactory alternative: I made a Shiva call – a condolence call – later at the home.

Nevertheless, sometimes it is a very good strategy to set a time limit to manage the pace of the negotiation, and sometimes one can thereby avoid a marathon session and get to peace in good time.


David I. Karp is a full time mediator of real estate and business disputes in Southern California. For additional information, please go to his business website at .


From → Mediation

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