Steven Benmor will initially meet with each spouse separately to understand his/her concerns, hopes and objectives, and to conduct screening, qualification for mediation and a design of the process. 

After the initial sessions, a teleconference will be held with the spouses and/or lawyers to determine the next steps. 

In most cases, the mediation session will be scheduled for a full day. 

Each lawyer will email a brief in pdf format to Mr. Benmor five (5) business days before the scheduled mediation session which will be shared with the other spouse and lawyer.

Each brief must include the following information:

1. list of issues to be mediated
2. outcome/conclusion sought for each issue
3. whether temporary or final resolutions are sought
4. BATMA and WATMA (best/worse alternative to a mediated agreement)
5. sworn Financial Statement with last 3 years' Income Tax Returns, last 3 years' Notices of Assessment and last 3 paystubs of this year or proof of current income
6. proposed Divorcemate or MySupportCalculator calculations including all calculations, life insurance requirements and lump sums
7. Net Family Property Worksheet illustrating both positions
8. summary of law, if applicable
9. description of any language, religious or cultural needs 

1. the spouses and counsel present
2. the names and dates of birth of the spouses
3. the names and dates of birth of the children
4. the names of the lawyers
5. the date of marriage/cohabitation and date of separation (including multiple dates if applicable)
6. the issues mediated
7. the issues not resolved
8. the terms of the issues resolved (temporary or final)
9. any agreed upon next steps

*unless the spouses agree otherwise in the Mediation Contract

The Memorandum of Understanding is not binding, enforceable or considered a legal agreement. It, however, must be immediately reviewed by each spouse's lawyer to ensure that the spouses remain agreeable to its terms and so that a Separation Agreement may then be prepared based upon its terms. 

Once all issues are resolved, Mr. Benmor will draft a Separation Agreement within 30 days for review by the spouses and lawyers. Any disagreements in respect of the Separation Agreement will be mediated. In cases of mediation/arbitration, where mediation fails, the remaining issues may be submitted to arbitration by an affiliated arbitrator. 

In mediation/arbitration, Mr. Benmor will determine when the mediation stage begins and ends, and when the arbitration stage begins. Mr. Benmor may refer issues to arbitration for preliminary or temporary issues. In such cases, the spouses and lawyers will be issued a Notice of Arbitration defining the issues to be determined, and the affiliated arbitrator will then convene a teleconference with the spouses and/or lawyers to determine the scheduling of next steps. 

All mediations, arbitrations and mediation/arbitrations are confidential. Other than the Memorandum of Understanding and Notice of Arbitration, no reports will be issued. Lawyers, mental health professionals, other professionals involved and administrative staff cannot be compelled to testify in any court proceeding or to produce any data (except any mandatory report made to a Children’s Aid Society, the police or other legal authority such as if a child is at risk of harm, a person is in imminent danger, a judge orders disclosure or the police demand disclosure).