Mediation is more often than not a negotiation about money. Of course, non-monetary issues may also be involved. But all too often, back and forth negotiation over money (“positional bargaining”) reaches an impasse. That raises the question, what tools are available to the mediator, the parties and their counsel when negotiations break down? 1) First, it cannot be overemphasized how important it is for the parties to “set the table” even before they attend the mediation. If t