In divorce mediation, ask for clear terms on six fronts: the parenting schedule, child and spousal support, the family home, division of assets and debts, insurance coverage, and tax treatment - plus the small practical items people forget, like holiday rotations, travel consent, and who keeps the frequent flyer miles.
The parties set the agenda in mediation - not a judge, not a form. That freedom is the process's greatest strength and its quiet risk: anything you do not raise does not get resolved, and unresolved items become next year's conflict. The preparation that matters most is therefore a complete list, sorted by priority, before your first session - paired with the documents in our divorce mediation checklist. This article gives you the full inventory and a simple method for ranking it. It is general information, not legal advice - and because mediation is not legal representation, have an independent attorney review any agreement before you sign. For the process itself - court-ordered vs private, costs, timeline - see our complete guide to divorce mediation in Florida.
The parenting plan: more than a schedule
If you have children, the parenting plan is usually the most important - and most detailed - part of the agreement. A durable plan answers not just 'who has the kids when' but how the two of you will operate as co-parents for years:
- The regular weekly timesharing schedule, including exchange times and locations.
- Holiday, school-break, and summer rotations - specific, not 'we will alternate fairly.'
- Decision-making: how education, healthcare, and religious choices get made, and what happens on deadlock.
- Communication rules between co-parents (method, response times, what belongs in writing).
- Travel: consent requirements, passports, out-of-state and international trips.
- New partners, relocation notice, and how future schedule changes will be handled.
Money: support, in both directions
Support conversations cover child support and, where relevant, spousal support (alimony). Florida uses statutory guidelines for child support, so much of that discussion is about accurate inputs - incomes, overnights, insurance and childcare costs - rather than free negotiation. Spousal support is more open-ended: amount, duration, and whether it can be modified are all terms to discuss.
Ask explicitly about the mechanics, because mechanics are where post-divorce conflict lives: payment method and date, what happens on job loss, when support ends or steps down, and how children's extras - sports, tutoring, braces, college - will be shared. A number without mechanics is half an agreement. (After the divorce, our guide to talking to your co-parent about money helps keep those mechanics working.)
The house: three paths, each with follow-up questions
| Option | Key questions to resolve in mediation |
|---|---|
| Sell and split proceeds | Listing timeline, agent selection, price decisions, who pays the mortgage and upkeep until closing, how proceeds divide |
| One spouse keeps it | Buyout amount and timing, refinancing deadline to remove the other's name, what happens if refinancing fails |
| Keep it temporarily | Who lives there and until when (for example, until the youngest finishes school), who pays what, the trigger for eventual sale |
The full asset and debt inventory
Beyond the house, build a complete inventory - the agreement can only divide what is on the table:
- Bank accounts, investment accounts, and cash.
- Retirement accounts and pensions - division often requires special orders; flag this for attorney follow-up.
- Businesses or professional practices, and how they will be valued.
- Vehicles, boats, and equipment.
- Debts: mortgages, car loans, credit cards, student loans, personal and tax debts - and who is responsible for each going forward.
- The forgettable items: airline miles and points, cryptocurrency, season tickets, timeshares, collections, tools, photos and digital archives, and pets - who keeps them and whether there is a care arrangement.
Debts deserve as much attention as assets
A creditor is not bound by your divorce agreement - if your name stays on a joint card or loan and your ex stops paying, the creditor can still pursue you. Ask in mediation about closing joint accounts and refinancing debts into one name, and confirm the details with independent counsel.
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Who is this mostly about?
Insurance, taxes, and the fine print that isn't fine
- Health insurance: who covers the children, how uncovered medical costs split, and coverage for a spouse losing employer insurance.
- Life insurance: whether policies will secure support obligations, in what amount, and who verifies beneficiaries annually.
- Tax treatment: who claims the children in which years, filing status for the transition year, how capital gains on the house sale are handled, and the tax character of any support - flag all of it for a tax professional.
- Name change, if wanted - easiest to include now.
- Beneficiary updates on retirement accounts, life insurance, and wills - and a deadline for making them.
- A dispute-resolution clause: agreeing now to return to mediation before court if future disagreements arise.
Turning the list into a priorities strategy
A complete list is raw material; a priorities list is strategy. Take every item above that applies to you and sort it into three tiers: must-have (the few items you would not sign without), matters-but-flexible (real preferences with acceptable alternatives), and tradeable (items you can concede to protect tier one). Be honest - if everything is a must-have, nothing is. This tiering method works in any negotiation, and our broader guide to preparing for mediation pairs it with the walk-away analysis that keeps you steady under pressure.
Then, for each must-have, write one sentence on why it matters. Mediators can work productively with interests ('I want the kids' school life to stay stable') far better than with positions ('I get the house, period') - the why is what opens alternative solutions you have not thought of yet.
Preparation meets structure
Dr. Conflicts divorce mediations are led by Sapir Saadon, a Florida Supreme Court Certified Family Mediator, in a structured, confidential process that works through exactly these categories methodically - so nothing important gets skipped. Virtual sessions are available across Florida.
What not to ask for
Two categories reliably waste sessions. First, punishment: terms designed to hurt rather than resolve tend to collapse in negotiation and poison the co-parenting relationship you will still have afterward. Second, control over the other person's future life - who they date, how they parent on their own time within normal bounds - which is generally neither agreeable nor enforceable. Spend your leverage on the things that shape your actual future: time with your children, financial stability, and a clean separation of obligations.
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Frequently asked questions
What documents should I bring to divorce mediation?+
Recent tax returns, pay stubs, bank and investment statements, retirement account statements, mortgage and loan balances, insurance policies, and a list of major assets and debts. Organized documents shorten the process and lower its cost.
Can we mediate if we cannot agree on anything right now?+
Often, yes. Mediation exists precisely for people who cannot agree on their own - a structured process and a neutral mediator change the dynamics. Willingness to try is required; pre-existing agreement is not.
What if my spouse hides assets during mediation?+
Honest financial disclosure is foundational, and Florida divorce cases involve financial disclosure requirements. If you suspect hidden assets, tell an independent attorney - discovery tools exist for that, and agreements built on fraud can be challenged.
Do we have to resolve everything in one mediation session?+
No. Divorce mediation commonly runs across multiple sessions - for example, parenting first, finances second. Complex issues can wait while appraisals or advice come in, and partial agreements can be documented along the way.
Can we change the agreement later if life changes?+
Some terms - especially parenting and support - can typically be modified through the court when circumstances substantially change, and parties can agree to return to mediation first. Property division is generally final. Ask an attorney which of your terms are modifiable.
Should I ask for the house or the retirement account?+
There is no universal answer - it depends on liquidity, taxes, upkeep costs, and your long-term plans. A house and a retirement account with equal balances are not equal in practice. This is a question worth putting to a financial adviser before you decide.
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