This POS presentation teaches mediators what should be done in order to have an effective and productive opening statement from each party. The past can have a powerful hold on parties in conflict. Respecting the past, while moving beyond blame can be a delicate part of any resolution process. While it is important for parties to hear each other’s concerns, allowing an opportunity to vent, within a safe and structured context, the conflict runs the risk of escalation and the parties could become explosive. The skills taught in this lesson, including how to deal with interruptions, the power of active listening, and effective note taking (with examples) will help mediators navigate through the parties’ past.