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This the 4th part in a series of blogs designed to help you prepare for your own negotiations. Find the first blog here. 

In preparing for your negotiation, you have decided to explore your own role in the impending story of conflict. This work takes courage and discipline. It means you acknowledge your emotions but you do not let them control you. This begins by unpacking your own story. 

Take a blank sheet of paper with a line down the middle.

On the left side of the page write down all the facts as they occurred and as objectively as possible. This is just the confirmed facts, just what actually happened. On the right side of the page write down what you made those facts mean. These are your judgements, assumption, and interpretations.

Work hard at this and make it as complete and accurate as possible. Get help with this if you need it.

Next take another sheet of paper with a line down the middle.

On the left side of the page make your best guess as to how you think the other side in your conflict sees the facts. Based on their reactions to date what do they think happened? On the right side of the page make your best guess as to what their meanings might be—their own judgements, assumptions and interpretations.

Again, if you have someone who is knowledgeable about both stories and objective, they can be extremely helpful in this process.

As you study these pages you will begin to see the factual disputes that need to be addressed. I think you will also notice that much of your conflict exists on the meaning side. This is a simple tool with a tremendous impact on your preparation for your negotiation.

In my next blog I will discuss how to compare and clarify your findings to identify what really matters. For more information about the design of your mediation please contact us at:

Your questions and comments are welcome and appreciated.

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David Gould (LLB, QC, C Med) has helped hundreds of lawyers and their clients – business and government organizations, and individuals – in conflict situations to co-create solutions for the future. For more information, contact: or visit