Meier & Barlow
Reason. Respect. Grace
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Preparation For Mediation in a Divorce

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While it is okay to attend your first mediation session with very little preparation, it will undoubtedly be more efficient and likely less expensive to consider the following prior to same:


  • Goals/ Objectives for Mediation Session


  • Child Custody
  • Parenting Time- ordinary, vacation, holiday
  • Out-of-Pocket Costs Regarding the Children (medical, school, extracurricular)
  • Other Agreements Regarding the Children or Household
  • Child Support
  • Tax Filings, Deductions, and Exemptions


  • Double check your AOC-238 and 239 Financial Disclosure forms, as well as your Interrogatory/Discovery Answers and get updated balances, statements, and budgets, if necessary. The more current the financial picture, the more confident you will be in deciding whether to reach an agreement.

A good start would include the following documents/ information:

  • Last six pay stubs
  • Last three federal and state tax returns
  • Cost of all insurance (even if you don’t carry it now) - If child support is contemplated, you’ll need the cost of health insurance for you alone and the cost to insure you and the child(ren). You can get this from your HR department.
  • Value of the real estate (appraiser) and cars (Kelly Blue Book)
  • Balances in bank accounts
  • Investment balances
  • Retirement balances/values and conditions on dividing them
  • Life insurance cash values, beneficiaries, and values
  • List of personal property left to divide
  • List of all debt with current balances
  • Updated budget, including budget for anticipated change of residence


  • Consult with your CPA or book keeper regarding tax considerations that you may need to take into account.
  • Consult with your investment advisor regarding division of assets, future financial planning, income questions, and the like.
Ashley Barlow