Tag Archive: Mediation


In recent days, it has been reported that the City of Detroit may be next in line for a Chapter 9.  The city’s top options are for Michigan Governor Rick R. Snyder to appoint a financial manager, file bankruptcy, or submit to neutral evaluation or mediation.  Last week, a review team assembled by state Treasurer Andy Dillon said that all signs point to a Motor City financial emergency.  As reported by The Huffington Post on Thursday:

With 700,000 residents, Detroit could become the largest city in American history ever to enter Chapter 9 municipal bankruptcy. But Snyder has stated that he’s reluctant to go down that path.

While the governor has several options under Michigan law for dealing with the city’s financial emergency, a major tug-of-war has revolved around Michigan’s emergency manager law, Public Act 4.  The so-called PA4 replaced its predecessor Public Law 72 in 2011 under Snyder’s watch.  PA4 was repealed by voters in November 2012.  More recently, however, “Republican lawmakers . . . passed a new emergency manager law, known as Public Act 436, which goes into effect March 28 . . . . Much like PA4, the new law vests emergency managers with considerable powers over the municipalities they are appointed to run.”

PA436, however, provides for a neutral evaluation or mediation option.  Although mediation has not been a top consideration thus far, it is available to leaders as an alternative to the appointment of a financial manager or Chapter 9.  Governor Snyder has said he supports giving interested parties, including the local government, bondholders, unions, and pension funds, and the city’s creditors an opportunity to compromise.

The review team noted the severity of the city’s financial crisis:

Detroit’s unfunded pension liabilities and long-term debt total almost $15 billion, and without new budget cuts or an infusion of cash, the city’s short-term debt for the fiscal year ending in June will top $100 million. As soon as this summer, Detroit may not be able to pay city workers, staff fire engine rigs or mow the grass at the city’s under-maintained parks.

These projections apparently only underscore the city’s fiscal situation, as “auditing errors, operational dysfunction and systemic challenges [also] hamper reform.”  Additionally, protestors, including mostly African-American activists, have “opposed state intervention . . . call[ing] the [emergency manager] law undemocratic . . . .  [joining] hands [in the governor’s office building] pray[ing] for local control. ”

“Mayor Dave Bing . . . has insisted his administration is capable of solving the city’s financial problems without a state takeover.”  The city’s other politicians and citizens, however, have voiced differing opinions regarding the financial manager and bankruptcy options.  See
Letters: An emergency manager or bankruptcy for Detroit?, The Detroit Free Press, http://www.freep.com/article/20130301/OPINION04/303010036/Letters-An-emergency-manager-or-bankruptcy-for-Detroit-?odyssey=mod_sectionstories, Mar. 1, 2013.

Source:

Quotations from Ashley Woods, Detroit Financial Emergency: Is Mediation An Option For Michigan Gov. Rick Snyder?, The Huffington Post, http://www.huffingtonpost.com/2013/02/28/detroit-financial-emergency-neutral-evaluation_n_2741938.html, Feb. 28, 2013.

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To follow-up on my October post, “Could the NHL Lockout Benefit from a Mediator?,” as of Monday, November 26th, the parties reported an agreement to mediate.  Three neutrals from Federal Mediation and Conciliation Service have been assigned.  The sides met separately with the mediators on Wednesday, November 28th.

“Hockey players and management have not negotiated since last Wednesday [November 21, 2012]. The NHL has canceled more than one-third of its regular season, including all games through Dec. 14, the New Year’s Day outdoor Winter Classic and the All-Star weekend scheduled for Jan. 26-27 at Columbus, Ohio.”  NHL Lockout 2012: Federal Mediators Set To Join Stalled Labor Talks, The Huffington Post, http://www.huffingtonpost.com/2012/11/26/nhl-lockout-2012-federal-mediators_n_2194463.html#slide=1663482 (Nov. 26, 2012).

Although many may be satisfied with what seems like progress between the parties in agreeing to mediate in the first instance, others note that the mediation may not guarantee a successful end to the lockout.

Gary R. Roberts, dean and professor of law at Indiana University, and sports labor law specialist (and also my former Sports Law professor at Tulane), provides this take:

My guess is just based on past history and the tone of the way things are going right now is that this is probably not going to produce a settlement . . . . This isn’t like a hysterical couple doing divorces or a commercial dispute where one side or the other is just being totally unrealistic. These are two very sophisticated and experienced groups. I just don’t see how much a mediator can bring to the table other than to remind them of what’s at stake periodically. . . . Who knows how many seeds the mediator might plant that could eventually bear fruit . . . . It’s hard to predict. . . . Mediation tends to me a mechanism whereby tempers can be cooled, and people who are operating from unrealistic perspectives can be brought to see what reality is . . . . It sounds like they’re pretty much at an impasse . . . . Both sides have their perspectives and their objectives and neither side can accept a set of proposals that the other side insists is necessary. We really are at sort of a standstill.

Stephen Whyno, NHL lockout 2012: Reality is, mediation might not solve anything, The Washington Times, http://www.washingtontimes.com/news/2012/nov/27/nhl-lockout-2012-reality-mediation-might-not-solve/#ixzz2Dg1aKVWO  (Nov. 27, 2012).
“About $182 million apart on core economic issues, there’s further disagreement on matters such as contract length (players want none while owners want to institute a five-year limit) and arbitration rights.”
-Whyno (article link above).
Can a mediator bring them together?  What’s your take?

Actually, for me, it was a Suzy Q.  You see, I had a “friend” that I frequently shared lunch with in elementary school.  She bought the school lunch and I packed my lunch (except Thursdays–pizza day!).  My parents filled our lunches with healthy, nutritious foods.  But, occasionally, we received a treat in our lunches as well.  When my mom brought home that Suzy Q, I lost it.  Oh, the decadence.

Well, by “lost it,” I don’t mean that I jumped for joy, or sang my mom’s praises.  I sat down on the steps leading from our kitchen to our family room and burst into tears.  I just couldn’t bare to share my delectable treat.  So, I spilled all the beans.  Finally, my mom understood why I was so hungry after school.  Half of my lunch had been someone else’s midday nourishment.  That stopped the very next day.  MY Suzy Q gave me the power to take back all of my lunch!

Similar to my tale, the current news on the Hostess Brands, Inc. financial demise, mediation and imminent liquidation has sparked up nostalgia.  Across the country (and likely the world), people are remembering their favorite Hostess treats, with several reclaiming them in hoards at local stores last week.  Suzy Qs are even being sold on eBay!  I haven’t had a Hostess treat in years, but I remember the taste well.

It’s been said that Twinkies have a shelf life of 20 years or more–a common urban legend, I suppose.  Our Twinkies survived the days of being tossed in paper sacks or metal lunch boxes with the likes of ET, Care Bears, GI Joe or Barbie gracing the outside.  They were kept in our paper lunch sacks or boxes, with a collection of other lunches, in our classrooms or classroom coat rooms.  There was no refrigeration for our lunches or cold packs to keep them at the right temperature until the school bells signaled the start of the lunch hour.  Indeed, the closest thing we had to a cold pack was a thermos that frequently allowed us to carry warm soup to school for lunch, or better yet, “lukecold” milk.

So, if our Twinkies could survive all of that, I am certain they will survive this.

What was your favorite Hostess treat?

A) Twinkies

B) Ding Dongs

C) Crumb Cakes

D) Ho-Hos

E) Other

Be sure to follow current events on the Hostess Brands, Inc. bankruptcy under the Roll Call tab.

My definition of bankruptcy mediation is below.  What’s yours?

The process by which a neutral third-party facilitator assists parties in the negotiation and resolution of bankruptcy-related disputes that can be available at any point during a commercial or consumer bankruptcy proceeding when: (1) the parties and their legal counsel agree to participate in the mediation process, and (2) the process is approved by the bankruptcy court.

 

Picture this . . .Widget Factory has been providing widgets to Small Business for 5 years.  In those 5 years, Small Business paid each invoice within 30 days of receipt.  The past 6 months of payments, however, have been a bit more suspect.  Small Business began making payments over 30 days past the date of invoicing and missed a few payments here and there.  But, Small Business doubled up on a couple of invoices in the last 90 days to catch up.  After struggling financially to keep up with creditors and the demand of its customers, Small Business filed for bankruptcy protection.  Upon review of Small Business’s schedules and questioning during the meeting of creditors, the trustee filed an adversary proceeding to recover the payments made to Widget Factory in the 90 days before the bankruptcy filing.  This is what the bankruptcy world affectionately refers to as a preference action.

The focus of this post, which is Part I of II in a mini-series on mediating preference actions, is to generally (very generally!) define and outline the elements of a preference action.

Preference claims customarily arrive as a demand to repay amounts the creditor received from its customer in the 90 days before the customer’s bankruptcy case . . . . To many creditors, preference claims come as surprises.  After all, there is no dispute that the customer owed the debt and the creditor earned the payment.”  Often, creditors view preference claims as unfair, asking why they should be required to repay monies that were legitimately due and owing to them. Under ordinary business circumstances, this position in well-taken.  But,”[t]he primary underlying principle supporting the return of preferential payments is the fair and equal treatment of all unsecured creditors.  Disgorging payments made is intended to redistribute the bankruptcy estate’s assets equitably among all of the unsecured creditors. . . . [C]reditors who repay preferences will hopefully recover at least a part of what they returned by participating pro rata in distributions with other unsecured creditors. . . . Section 547 does not require ‘intent‘ to receive a preference, notice of insolvency, fraud or any other subjective element.  Because the policy behind the preference statutes is equal distribution, intent or notice is irrelevant.”

So, how do we know if a payment is a preference?  Preferences are defined under Section 547 of the Bankruptcy Code by the following five elements:

  1. A transfer of an interest of the debtor in property to or for the benefit of a creditor;
  2. A transfer for or on account of antecedent debt owed by the debtor before such transfer was made;
  3. A transfer made while the debtor was insolvent;
  4. A transfer made during the preference period (the Bankruptcy Code presumes that a debtor was insolvent in the 90 days before the petition date and the reach-back period is extended to one year for insiders—family members, business partners, etc.); and
  5. The transfer enables the creditor to receive more than if the case preceded under chapter 7.

No, no you say, that isn’t right.  Shouldn’t the creditors have some defense?  Well, of course.  There are 10 of them:

  1. The transfer was made in a contemporaneous exchange of new value to the debtor;
  2. The transfer was made in the ordinary course of business;
  3. The transfer was a security interest in property securing a new value to the debtor;
  4. The transfer was made after the creditor provided new value;
  5. The transfer was a security interest in inventory or a receivable;
  6. The transfer was the fixing of a statutory lien;
  7. The transfer was of an alimony or child support payment;
  8. The transfer was of property with an aggregate value less than $600 in a case involving primarily consumer debt;
  9. The transfer was of property with an aggregate value of less that $5,475 in a case not involving consumer debt; or
  10. The transfer was pursuant to an alternative repayment schedule.

There are also several other defenses that are specific to particular industries, such as grain producers, fishermen and warehousemen.

As you would imagine, the assertion of preference claims and affirmative defenses, lead to a flurry of negotiations, charts, documents, calculations and other supporting evidence to whittle down what amount of the questioned payments are actual preferences, if anything.  This is why preference actions are often the subject of mediation.

Stay tuned for Part II on how mediation can be used in preference actions.

Sources:

Quotations and excerpts from Wheeler, David B., ABI Preference Handbook, American Bankruptcy Institute (2d ed. 2008), at 1, 3, 8–21, 29, 36–38.

11 U.S.C. § 547(b) (Elements of Preference Claim).

11 U.S.C. § 547(c) (Affirmative Defenses).

“A federal judge on Monday handed partial victories to both the Archdiocese of Milwaukee and the sex abuse victims who make up the vast majority of creditors in its bankruptcy.  The ruling, by U.S. District Judge Rudolph Randa, lets stand a February decision by U.S. Bankruptcy Judge Susan V. Kelley dismissing one victim’s claim and allowing two others to move forward, at least for now.”

Annysa Johnson, Judge lets archdiocese bankruptcy abuse ruling stand, http://www.jsonline.com/features/religion/judge-lets-archdiocese-bankruptcy-abuse-ruling-stand-1l7d86f-176360111.html (Oct. 29, 2012) (emphasis added).

_________

Post History

Archdiocese of Milwaukee Chapter 11 Mediation

  • UPDATE- As of Monday, October 15, 2012, it was reported that the mediation in the Archdiocese of Milwaukee Chapter 11 has failed.  Apparently, the estimated 570 victims and archdiocese were unable to reach a settlement.  The parties, however, have not provided any additional details regarding the reasons for the impasse.  As a result, the parties continue to pursue several pieces of litigation related to: (1) reduction of the number of eligible claims, (2) increasing the assets available to pay creditors, (3) the recovery of funds related to a certain cemetery trust created by the archdiocese in 2007, and (4) procedural claims–some of which are on appeal–regarding alleged venue shopping and to make public various discovery, which is currently subject to a protective order.

Sources:

Annysa Johnson, Milwaukee Archdiocese victims fail to reach bankruptcy settlement, Journal Sentinel, http://www.jsonline.com/features/religion/milwaukee-archdiocese-victims-fail-to-reach-bankruptcy-settlement-ii77put-174278861.html (Oct. 15, 2012).

  • The Archdiocese of Milwaukee, which faces more than a dozen civil fraud lawsuits over its handling of clergy known or alleged sex abuse cases, filed for Chapter 11 bankruptcy protection in January 2011.  Currently pending before the mediator, retired U.S. Bankruptcy Judge Randall J. Newsome, is the issue of whether an estimated 570 victims should be compensated, and if so, the extent of such compensation.  As of October 3, 2012, Judge Susan V. Kelley, who has raised concerns over increasing legal fees, granted a second mediation deadline extension to October 12, 2012.

Sources:

Annysa Johnson, Archdiocese bankruptcy mediation extended, Journal Sentinel, http://www.jsonline.com/blogs/news/172543611.html (Oct. 3, 2012).

Milwaukee Archdiocese, bankruptcy creditors to enter mediation, Journal Sentinel, http://www.jsonline.com/news/milwaukee/milwaukee-archdiocese-bankruptcy-creditors-to-enter-mediation-r960mvk-161244745.html (July 3, 2012).

Tip for the Mediator

Don’t give up on a case too early.

If the parties have not reached an agreement, stick with them after the mediation session ends.  Offer to follow-up and seek updates from the parties regarding any new information discovered and exchanged, and any changes in the parties’ positions.  Follow-up on prior matters you have mediated at least one hour every day.  This could lead to a secondary mediation.

Consider this scenario:

Critical Vendor  (“Critical”) has been doing business with Great Expectations Theater of International Talent  (“GETIT”) for over 20 years.  Actually, Critical has been in the trenches with GETIT since its opening.  Over the years, Critical has supplied dance shoes (i.e. ballet slippers, tap shoes, jazz shoes), leotards, tutus (similar to the multitude of taffeta and mesh skirts trending now), stage make-up, lighting, props and music (on cassette, CD and MP3 formats).  There was never a time when Critical could not meet GETIT’s supply demands.  For the first 15 years of the business relationship, GETIT timely paid every invoice and used Critical for all theater and production-related needs.  GETIT provided Critical with so much business that GETIT was always Critical’s top customer and frequently its only customer.  The owners of each operation also became close friends and often took family vacations together.  Their children were around the same ages and attended the same schools.

The last five years, however, have not been as copacetic.  You see, with the combination of in-home entertainment, the nearly bottomed-out economy and sundry reality TV options, audiences were no longer flocking to GETIT’s productions.  Sales receipts and annual memberships were down.  GETIT went from nightly shows and matinees on each weekend day to three shows per week.  Then, eventually, one show per week.  During that phase, Critical’s owner donated supplies, heavily discounted bills and offered to invest in GETIT, all to save the company she essentially helped to build for 15-20 years.  Plus, she wanted to help her friend, to whom she attributed much faith and loyalty, and could not bare to see GETIT collapse.  Even in light of her willingness to help, Critical’s owner was still a “savvy” businesswoman and often felt foolish for financially helping a friend’s company.  She knew that could be a significant mistake and could negatively impact Critical.  But she did it anyway, while periodically asking GETIT’s owner if she was contemplating bankruptcy.  GETIT’s owner always shrugged off such inquiries, but offered a trifling bit of reassurance, saying, “If I do decide to file, you’ll be the first to know.”

Turns out, Critical’s owner was not the first to know.  Indeed, she did not learn of GETIT’s Chapter 11 filing until she received a copy of GETIT’s petition and schedules in the mail.  Critical was listed in GETIT’s schedules and a related motion as a critical vendor with a sizable prepetition unsecured claim.  Although the practical benefits of retaining a critical vendor in restructuring and reorganization proceedings is to avoid the disruption of the debtor’s business, Critical wanted out.  Critical’s owner knew that her prepetition unsecured claim could be zeroed out, or at best, receive only pennies on the dollar.  If GETIT’s motion was granted, Critical would have to continue to meet GETIT’s supply demands.

Therein lied the dispute.  Critical heavily objected to GETIT’s motion to approve its proposed critical vendor status, which led to thousands of dollars of motions practice and litigation.  Prideful and equally humiliated, the parties refused to speak during the contentious time, but eventually agreed to mediation.

The bankruptcy court-approved mediator worked diligently with the parties to guide them to a resolution.  Upon the parties’ impasse on several occasions, the mediator continued the mediation and followed up with the parties after the failed sessions, which brought the parties back to the table each time.  Frustrations, anger and even rising prejudices by Critical’s and GETIT’s counsel, stalled each attempted mediation session.  Not to be deterred, the mediator took one last shot at getting the parties to a potential resolution and pondered what method or tactic might work best.  Finally, she believed she knew the true basis of the contention.

She went into a caucus, or private meeting, with each party.  In the caucus with Critical’s owner and counsel, she looked Critical’s owner squarely in the eyes and said, “I think what you are seeking from this is something deeper yet more basic and personal than all of the legal issues you all have tossed back and forth for months.  Tell me what that is.”  Critical’s owner peered back at the mediator; her eyes revealed the competing emotions of perplexity, anger and relief.  Finally, she said, “All this time, I just wanted GETIT’s owner to apologize.  She never said, I’m sorry.  She drug me into this.  I asked many times if she was planning on a bankruptcy and she gave me no heads up.  She told me she would.  I took her word.  Now, my business is on the brink of collapse, and she never even said, ‘I’m sorry.'”

At the end of the day, GETIT’s owner delivered the long-awaited words, “I’m sorry,” and the parties moved forward to an agreement.
So, what’s the moral of the story?  Sometimes, the legalities, the substantive law, bankruptcy code and rules are not enough.  Often, the “Golden Rule” wins out.  When faced with these types of circumstances as a mediator, or practitioner representing emotionally torn, humiliated and embattled parties, start with that rule first.  You’re likely to avoid the complexities of pride and prejudice.  Get it?

Let me know how you would you have handled this situation.

As of Monday, October 15, 2012, it was reported that the mediation in the Archdiocese of Milwaukee Chapter 11 has failed.  Apparently, the estimated 570 victims and archdiocese were unable to reach a settlement.  The parties, however, have not provided any additional details regarding the reasons for the impasse.  As a result, the parties continue to pursue several pieces of litigation related to: (1) reduction of the number of eligible claims, (2) increasing the assets available to pay creditors, (3) the recovery of funds related to a certain cemetery trust created by the archdiocese in 2007, and (4) procedural claims–some of which are on appeal–regarding alleged venue shopping and to make public various discovery, which is currently subject to a protective order.

Reading the new reports, it strikes me as ironic that this attempt at resolution and restoring peace among the parties, failed in a bankruptcy where the principal party involved is one that is frequently called as a mediator, or neutral.

What are your thoughts on why and how this attempted settlement and mediation failed?

Sources:

Annysa Johnson, Milwaukee Archdiocese victims fail to reach bankruptcy settlement, Journal Sentinel, http://www.jsonline.com/features/religion/milwaukee-archdiocese-victims-fail-to-reach-bankruptcy-settlement-ii77put-174278861.html (Oct. 15, 2012).

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Even in light of the litigious and adversarial nature of some matters nowadays, many parties are willing to engage in mediation to attempt to resolve matters or various sub-issues.  I have heard from several practitioners, however, that while the mediation process allowed their clients to tell their stories through caucusing and/or facilitative discussions with the other side, the mediation did not yield any significant movement in their interests.  As a result, they left the mediation table still touting their positions and had not moved closer to settlement.  In fact, a few practitioners have stated that they wished the mediator was more helpful in getting their client to understand the weaknesses in their position.  Well, the parties and the mediators in those situations were likely approaching the mediation from different perspectives; perhaps they were respectively viewing the process through evaluative and facilitative lenses (or some other lens).

There are several forms of mediation.  For an effective mediation process, it is important for practitioners to understand each method, agree on an approach for the mediation and communicate the same to the mediator.  So, what types of mediation exist?  There are four widely recognized approaches, although the methods and approaches are not just limited to the following.

First, Evaluative Mediation “is generally understood to be a process which may include an assessment by the mediator of the strengths and weaknesses of the parties’ cases and a prediction of the likely outcome of the case. . . .  Some parties wish to retain an evaluative mediator to help them get an objective view of their case and to prod the parties to reach a reasonable settlement based upon the merits of their case.”  Although every circumstance should be evaluated differently, it is likely that parties mediating bankruptcy-related issues may be seeking more of an evaluative mediation process, because of the need to resolve such matters on a “faster track.”  Further, evaluative mediators are more likely to be chosen for their subject matter expertise, which may be beneficial in the bankruptcy context.  After all, under this approach it would be important for the mediator to know the difference between valuation issues, contested confirmation hearings and preference actions.  Evaluative mediation, however, should not be confused with neutral evaluation, or a neutral evaluator’s approach.  “Neutral evaluation is a disciplined and principled process.  The neutral is chosen for knowledge and experience and listens to the arguments of both sides, researches the matter and comes up with an opinion.”  An evaluative mediator, on the other hand, may or may not give an opinion and/or a proposal for settlement.

Second, Facilitative Mediation is probably the most common approach people think of when they hear the word mediation.  Facilitative mediation is the process by which the mediator “helps parties think about how to work through difficulties and toward a resolution of their own making [if so desired] without outside pressure.”  Under this approach, “[t]he mediator asks questions; validates and normalizes parties’ points of view; searches for interests underneath the positions taken by parties; and assists the parties in finding and analyzing options for resolution.  The facilitative mediator does not make recommendations to the parties, give his or her own advice or opinion as to the outcome of the case, or predict what a court would do in the case.  The mediator is in charge of the process, while the parties are in charge of the outcome.”

Third, Transformative Mediation,  in some respects, appears to be a hybrid of the common approaches.  The distinguishing factor is that the ultimate goal is for the parties to leave the mediation with an improved relationship.  “The parties . . . work with the mediator to determine the appropriate resolution process for their situation. . . . Recognition is generally considered to be an important part of transformative mediation, so that each party can understand how the other one defines the problem.”  This approach is often used to resolve workplace conflicts, because the conflicting parties typically continue to work together.  Transformative mediation, however, could easily be extended to bankruptcy cases where parties such as lenders and debtors, debtors and creditor-suppliers and debtors and landlords need to maintain a continuing relationship during and after the bankruptcy case is closed.

Fourth, “Narrative Mediation builds on the storytelling metaphor.  It is both an approach and a methodology, providing mediators with a way of incorporating stories into the very fabric of mediation.”  This allows parties to move from positions of “victimized and protagonist” and “victimizer and antagonist,” to a shared story without pinning the responsibility for the conflict on any one side.  “This leaves conflict parties with a previously ‘closed’ interpretation (their story) open to new possibilities and interpretations.”  The ultimate goal is that through storytelling, the parties move toward a “new climate of openness [leading] to the genesis of  a new account [story] and mutually satisfying interpretations and outcomes.”

While there are several approaches to mediation, the takeaway here is that the parties should work together to agree on a method, communicate that approach to the mediator and re-evaluate where necessary to change methods given the particulars of their individualized situations and any changed dynamics over time.  Mediators should also be clear to communicate their methods to the parties (whether it be one method or a combination of methods and approaches), encourage the parties to agree on the approach and understand what methods work best for specialized issues, matters and areas.

What method, if any, do you think best suits bankruptcy-related disputes?

Sources:

Zena Zumeta, Styles of Mediation: Facilitative, Evaluative and Transformative Mediation, http://learn2mediate.com/resources/nafcm.php.

Diane Cohen, Evaluative Mediation, http://www.mediate.com/articles/CohenDbl20110321.cfm (Mar. 2011).

What Facilitative Mediation Has to Offer, http://dianecohenmediation.com/site/what-facilitative-mediation-has-to-offer/ (Jan. 2010) (originally published at mediate.com).

Alison Faria, What is Transformative Mediation?, http://www.wisegeek.com/what-is-transformative-mediation.htm.

Toran Hansen, The Narrative Approach to Mediation, http://www.mediate.com/articles/hansenT.cfm (Sept. 2003).

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