If a mediator has asked you to send a statement before your custody session, you may be staring at a blank page wondering how to prepare a mediation statement without it turning into a long history of everything that went wrong. That’s the most common trap. A good mediation statement isn’t your whole story. It’s a short briefing that helps the mediator understand your family, the issues and what you’re proposing, so the session can focus on solutions.

This guide explains what a mediation statement is, who reads it, and how to fill in each section of our free template, with a short filled-in sample and the mistakes that make statements backfire. The sample is for illustration only; check your mediator’s instructions and local rules, and consider having an attorney review your statement before you send it or sign anything that comes out of mediation.

What is a mediation statement, and who reads it?

A mediation statement is a written summary you give the mediator before a session. It may also be called a mediation brief, position statement or pre-mediation summary; in a custody case, it’s sometimes simply called the parent’s statement. Private mediators often request one from each parent. Court-connected programs more often use their own intake form, though some ask for a statement too.

The mediator uses it to learn the background, spot the real disagreements and plan the session. It isn’t a court filing, and it isn’t evidence. Before you write a word, ask two questions:

  • Who will see it? Some mediators keep statements confidential. Others share them with both parents. Write as if the other parent will read it either way.
  • What format and length? Some mediators want a page; some want a specific outline. Their instructions override any template.

Download the template below, then follow the section-by-section guide.

How to prepare a mediation statement, section by section

Our template follows the order most mediators find useful. Fill in what applies, skip what doesn’t, and keep each section short.

  1. Heading. Your name, the other parent’s name, the case number if there is one, the mediator’s name and the session date. If the mediator asks you to mark it confidential, add that label exactly as instructed.
  2. Family snapshot. Each child’s first name or initials, age, grade and school. Describe the current living arrangement in one or two sentences, and list any existing orders, including temporary custody or protective orders.
  3. Where the case stands. What’s been filed, any temporary orders, upcoming hearing dates and any earlier mediation. Dates only, no commentary.
  4. What you already agree on. Even small things, like which school the child attends. Listing agreements shows good faith and narrows the work.
  5. Issues to resolve. A numbered list: the school-year schedule, summer, holidays, exchanges, decision-making, communication. One line each.
  6. Your proposal for each issue. Be specific about days, times and places. Follow each with two or three sentences on why it works for your child.
  7. Your child’s needs. School demands, activities, health or developmental needs, routines that matter, and anything about the child’s age that affects scheduling.
  8. Concerns. Factual and specific: what happened, when, and how it affects the child. Leave out labels and speculation.
  9. Where you’re flexible. Name the issues where you’d consider other options. This gives the mediator something to work with.
  10. Attachments. A proposed calendar, the school calendar, or your work schedule. Attach only what the mediator asks for or what directly supports a proposal.

For help choosing what to propose in the first place, see our guide on how to prepare for custody mediation, and for drafting the proposal itself, how to write a parenting plan.

What does a mediation statement example look like?

Here’s a shortened sample showing tone and level of detail. Replace every bracket with your own facts, and don’t copy anything that isn’t true for your family.

Sample mediation statement (excerpt, illustration only)

Mediation statement of [Your name], [Case number], session with [Mediator name] on [date].

Family: [Child’s initials], age [7], second grade at [school]. Since [month, year], [Child] has lived with me during the week and with [Other parent] every other weekend under a temporary order dated [date].

Already agreed: [Child] will stay at [school]. We both want [Child] to continue [soccer] on Saturdays.

Issues: 1. School-year schedule. 2. Summer. 3. Exchange location.

Proposal on issue 1: Keep the current weekday schedule and add a Wednesday dinner visit with [Other parent] from [4:30] to [7:30 p.m.]. [Child]’s teacher has noted [Child] does best with a consistent school-night routine, and this adds midweek time without an overnight transition.

Flexible on: Summer. I’m open to [two non-consecutive weeks] or [alternating weeks] and would like to discuss what fits [Other parent]’s work schedule.

Notice what’s missing: no adjectives about the other parent, no history of the relationship, and no claims the parent can’t support.

What should you leave out of a mediation statement?

What you leave out matters as much as what you include. Mediators read statements quickly, and a single inflammatory paragraph can color everything else. Leave out:

  • Labels and diagnoses you aren’t qualified to make, like “narcissist” or “unstable”
  • The full history of the relationship or the breakup
  • Accusations you can’t support with dates or records
  • Ultimatums, such as what you’ll do in court if you don’t get your way
  • Piles of screenshots or exhibits the mediator didn’t ask for
  • Private details like your home address if there are safety concerns, and account or Social Security numbers
  • Things your child told you in confidence, unless they bear directly on safety

How do you sound reasonable without giving everything away?

Mediators respond to statements that are specific, child-focused and calm. That doesn’t mean agreeing to everything. It means making your case through facts and proposals instead of adjectives.

  • Use dates and specifics. “Three late pickups in [month], on [dates]” is more useful than “always late.”
  • Tie every proposal to the child. Explain how it fits school, sleep, activities or stability.
  • Acknowledge the other parent’s role. One sentence recognizing what they do well signals that you’re there to solve problems.
  • Separate must-haves from preferences. You don’t have to label them in the statement, but knowing the difference keeps your proposals coherent.

How do you send it, and what happens next?

Once the statement is written, the logistics are simple but easy to get wrong when you’re stressed. Work through these before the deadline:

  1. Proofread for facts, not just typos. Check every date, time and name against your records. One wrong date invites the other side to question everything else.
  2. Save it as a PDF with a clear file name, such as your last name, “mediation statement” and the session date, unless the mediator asks for a different format.
  3. Send it the way the mediator asks, by the deadline, and confirm it was received.
  4. Keep an exact copy and bring a printed copy to the session so you can refer to your own proposals.
  5. Update the mediator if something changes before the session, like a new work schedule or a new temporary order. A short email is enough.

If you receive the other parent’s statement, resist the urge to send a point-by-point rebuttal. Note the two or three statements that really matter, with the facts you can support, and raise them calmly in the session or privately with the mediator.

What if there are safety concerns?

If there’s been domestic violence, threats or coercive control, mediation may not be required or appropriate in your case. Many programs screen for abuse, and parents can usually ask to be excused or to mediate separately, with the mediator meeting each parent apart. Raise safety concerns with the program privately rather than in a statement the other parent might read, and keep your address and routines out of anything shared. If you’re in danger, call 911. The National Domestic Violence Hotline is 1-800-799-7233, or text START to 88788. Our guide on domestic violence and custody mediation covers your options.

The faster way to back up every point

The hard part of a mediation statement isn’t the writing; it’s checking the facts behind it. Doing this by hand in Word usually means scrolling back through months of texts to confirm a date, digging a school email out of your inbox, and retyping all of it, then doing it again before the hearing if mediation doesn’t settle. Case Builder keeps a master timeline that collects dated events from your evidence, messages and hearings, each linked to its proof, and an issue workspace for every point you’re making. When you write “three late pickups in [month],” the dates and the messages are already in one place, and the same organized file carries forward to a hearing or to an attorney. See how the timeline works.

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For a printable list of what to bring on the day, see our custody mediation checklist.