Future focus
Often parties will need to have regard to the past because unless we understand our past we are likely to repeat it. However the sooner the parties can focus on what needs to happen or change or be put in place to resolve the current situation and secure a lasting settlement, the more productive can be the discussion. Many a mediation has foundered because the parties were unable to move beyond allocation of blame for water which has now flown under the bridge.

Variation and Review.
Consider whether you need rigid arrangements which finalise the issues. In the case of ongoing relationships where circumstances will inevitably change demanding new arrangements from time to time, you will probably need flexibility. In cases where flexibility is required often parties agree to a clause such as “This agreement may be varied by mutual agreement[ in writing ?] at any time”. On the other hand in cases where the relationship is likely to remain tempestuous ,special arrangements will be needed to resolve any ongoing impasses and informal flexibility may be counter-productive, as it may lead to chaos and even abuse.
It is important in ongoing relationships to consider whether the arrangements are to be formally reviewed in further mediation [or otherwise]after a set period.

When to settle
The advantages of settlement by the end of the mediation include that there is finality and certainty for you .However it is important where doubt remains in your mind on a rational basis, to adjourn the matter for further reflection and/or advice although this must be weighed against the possibility that in adjourning without final agreement the other party may change her/his mind and resile from proposals made or tentatively agreed.

Chris Phillips
I acknowledge the expertise of Dr. Rachael Field, Professor of law at Bond University Law School, who presented in 2017 on “Using Dispute Resolution processes in matters where there is a history of domestic and family violence”; and Krista L. Viar, of Hello Humankindness.org,who published a paper called “Debate with Kindness: How to disagree and still keep it Civil“ on September 29,2016