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Issues to Be Resolved in Divorce Mediation

Division of property and debts

  1. What property and debts exist?
  2. How is that property and debts to be valued?
  3. How are those property and debts to be divided?
  4. Do the parties agree on the value of the property and debts? If not, how will the property and debts to be valued?
  5. What will happen with the matrimonial home?
  6. How will you divide the household contents?
  7. How are pensions to be valued?
  8. Were there any property debts before the marriage?
  9. Was there an inheritance before or during the marriage?
  10. What debts were incurred during the marriage?
  11. What happens to businesses owned by the spouses together or separately?

Spousal support

  1. Is spousal support a consideration? For how much and for how long?
  2. What are the tax implications of spousal support?
  3. What will trigger a change or end to spousal support?

Child support

  1. Is child support an issue?
  2. Will there be a cost-of-living index increase?
  3. What amount of child support is appropriate? What does it cover?
  4. What will trigger a change or end to child support?
  5. How will special expenses be shared?
  6. Will there be an education fund?

Health Care and insurance

  1. If you have insurance, many expenses could be covered but you need to think about coverage for the children, possibly the other parent, and how this coverage will occur.
  2. How will uncovered health care expenses and deductibles be shared?

Life Insurance. If there is life insurance on either or both parties, you need to be aware of the type of policy/policies.

  1. Will the policy beneficiary stay the same or change?
  2. Who will pay the premiums?
  3. Is insurance needed to protect support?


Mary Sanger is a trained mediator in divorce and family mediation.