Mediation Checklist ...
7. Your party's opening statement
Your party will have the chance to make a statement at the beginning of the Mediation. Keep it brief - everyone has read the papers and this is not an adversarial hearing.
Introduce yourself, your client and anybody else in your party. Use first names rather than titles, e.g. this is 'John Browne', rather than this is 'Mr Browne'
Express your good faith and sincere desire to use the Mediation process to settle if at all possible (assuming it's true).
Briefly set out your case, why you hold that position, and explain why there are areas of disagreement with the other parties' positions. Avoid legal jargon or reading out a 'pleading'. You can use elements of the written statement if you like, and include 'soft' items that are of importance such as an apology or other items that a court could not consider.
Remember that this may be the first time that your client and the other party have seen each other for a long time - it is a powerful opportunity to dispel some of the "demonisation" that may have occurred.
Explain why contrary positions are held in good faith, and are not 'mere traversals'.