How to Prepare for a Child Custody Mediation Session


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Create a "Relationship Timeline"

Create a "relationship time line" that includes when you and the other parent met, when your relationship became serious, when you began living together, when you were married (if applicable), when you first separated, the total number of separations, the date of the last separation, and whether and when couples or family counseling was ever done. The mediator will be asking these questions to get a general idea of both you and the other parent, and will also use this as a test to see if you recall the same things and whether you both have the same understanding about your relationship. It will be very helpful to you to have prepared this in advance to remind yourself of the details of your relationship with the other parent.


Prepare a "Parenting Timeline"

Next, prepare a "parenting time line" addressing the following points: what was the custody timeshare during the first six months after separation; from the six-month mark to the end of the first year after separation; when were the significant changes in the amount of time each of you had custody over the next two years; and what is the current parenting plan the parents are using. Again, this is all information that the mediator will be asking, and it will be helpful to you to be prepared to answer these questions. As you create this timeline, there may be things that stand out, which will need further explanation from you; this is your opportunity to anticipate the problems, questions, and concerns that the mediator may have, and give yourself the opportunity to have answers at the ready.


Prepare a "Personal Timeline"

Prepare a "personal time line" that answers the following questions (if you have remarried, include your new spouse's family in answering these questions): o Are the child's grandparents on both sides living or dead, married or not? If living, where do the grandparents live, and are they a part of the child's life? o How many siblings do you have, and what is your relationship historically and presently with them? o What contact do you have with extended family? o Briefly, what was your life like from birth to age 12? From 12 to 18? From 18 to 30? o What is your educational history? o What is your work history? o What is your current living situation, including all the household members? o What is your drug and alcohol history, including DUIs and hospitalizations, if any? o What is your domestic violence history? Who was your family at these times?


Prepare Sample Parenting Plans

The mediator will want to see how flexible you and the other parent are in regards to timeshare and parenting issues, how you intend to co-parent with the other parent, and whether you are both putting the child's best interests ahead of your own wishes and desires. To that end, prepare 3-4 proposed parenting plans, ranging from the child living with you to one that is (and I am simply speaking in the vernacular here), "the nightmare you can live with." Again, this is only to help you, rather than a document to be presented to the mediator. It will help you to demonstrate that you have given a lot of thought to this situation and are considering all possibilities. Take into account your child's general developmental stage when preparing your parenting plans and you may find that speaking with a child psychologist will help. In fact, I believe that any independent research and consultation that you do will only help you in your mediation and in the hearing before the Judge, as you will


Prepare a List of Your Concerns

During the mediation, the mediator will ask you to state your concerns regarding the other parent's parenting. Prepare a list of what your concerns are, so that it can be reviewed and discussed in advance of the mediation session. Afterward, make a list of the things the other parent can do to reduce your concerns. The mediator will likely ask you that as well. Also, list the concerns that the other parent may have about you, and what you can do to address those concerns.


Prepare a List of the Factors that Make Your Home Best for your Child

Finally, prepare a list or simply be prepared to explain how your child will be accepted into your family and what arrangements and provisions will be made for him and his place in your home. This will also be very important to the mediator, who will want to know whether your child will have his own room -- a place that he knows is his, and how he will be integrated into your family. Please also understand that the courts believe it is very important to a child's development for them to have their own space in each parent's home, even when they are not in the house. That is, the mediator will want to know that your child has his own room, one that remains his even when he is with the other parent.



Determining child custody and timeshare is without a doubt one of (if not the) most difficult aspects of a Family Law proceeding. At its core, the basic focus and inquiry needs to be on the best interests of the children. Stick to that goal and plan accordingly, be willing and able to cooperate and co-parent with the other parent and demonstrate this to the mediator, custody evaluator and Court and you should be able to achieve successful results that work in your child's best interests. Good luck!

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Feinberg & Waller, APC

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Divorce is the process of formally ending a marriage. Divorces may be jointly agreed upon, resolved by negotiation, or decided in court.

Child custody

Child custody involves decisions about who will be responsible for a child, including parental rights, for both married and unmarried parents, and adoptions.

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