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Mediation Opening Statements: Shoulds, Should-Nots, and Should We Even Do Them?

February 22, 2023 @ 12:00 pm – 12:50 pm
Live GoToWebinar
$50 for ADR Section Members

Originally presented on Feb. 22, 2023, by Natalie Paskiewicz. Course number 6841 is approved for 1.0 General CLE credit; 1.0 CME credit. The course soon will be available for purchase as an online seminar (on-demand) and downloadable audio.

So, you want to skip the opening statements at mediation. Is that a good idea? Why are opening statements of value? How can you make the best use of the introduction and chance to set the tone for the mediation?

We will discuss:

  • Who is listening and who is the audience when presenting the opening statement?
  • How to set the tone for a productive mediation.
  • When an attorney’s opening statement isn’t helpful or necessary.
  • Tips for how to maximize the opening statement to get what your client wants out of the mediation.


  • What is an opening statement?
  • Who uses opening statements?
  • What benefits can an opening statement offer?
  • How are opening statements used most effectively?
  • Potential problems of using opening statements


  • Why are some attorneys doing away with openings?
    • Speed/cost
    • Keeping parties separate
    • Creating the wrong environment /inflaming
  • Potential outcomes of not using an opening statement


  • Using or not using openings
  • Set clear expectations ahead of time for clients
  • Communicate with opposing counsel
  • Getting results from your mediation

Image of a smiling woman with one hand lifted

Natalie Paskiewicz has practiced throughout the state of Florida in civil trial liability matters arising from premises liability, trucking transportation, automobile negligence, products liability, catastrophic injury, labor & employment, negligent security, and many areas in which she now mediates.

In addition to her mediation practice, Ms. Paskiewicz also serves as an arbitrator for the Financial Industry Regulatory Authority (FINRA) and the American Health Lawyers Association (AHLA). She is an Executive Council member of the Alternative Dispute Resolution section of The Florida Bar and serves on the Board of Directors of the Clearwater Bar Association Young Lawyers Division.

Natalie is originally from Pittsburgh, PA. She attended Florida Gulf Coast University in Ft. Myers, FL, where she received a scholarship to play on the women’s golf team. While attending law school at Stetson University College of Law, she interned in-house with Minor League Baseball, headquartered in St. Petersburg, FL, worked for well-known TV personality, Judge Judy, and clerked for a Sixth Judicial Circuit Judge.