Henning mediators resolve over 85% of cases, saving clients the cost, time, and uncertainty of trial. Our neutrals are among the most experienced in the Southeast.
What decides whether a case settles is the neutral in the room, and Henning's are among
the most experienced in the Southeast: decades at the negotiating table, the judgment to
read a room, and the candor to test a weak argument until both sides move. It's why
Georgia's leading litigators bring their most significant cases here, and keep coming
back. For 30+ years we've pioneered the collective-mediation model the
field now follows, earning the trust of the attorneys who rely on us when the outcome
matters most.
Resolved in a Day
Most cases settle in one session
Private & Privileged
Protected under Georgia's Mediation Act
Full-Day Hospitality
Private suites, lunch, free parking
How It Works
The Mediation Process
Every mediation is different, but follows a proven structure. Click each stage to
learn what happens and how to prepare.
01
Pre-Mediation
Parties submit position statements at least 5 business days before the session. The mediator reviews materials and may conduct brief pre-mediation calls or virtual meetings to understand key issues and dynamics. This proactive approach allows Henning's experienced mediators to enter the session fully informed, identify potential barriers to resolution early, and maximize the time available for productive negotiations on mediation day.
At Henning
What to Expect
Location
3350 Riverwood Pkwy, Ste 75, Atlanta GA 30339, minutes from I-285 and I-75. Free parking in the building garage. Multiple private conference suites allow simultaneous separate caucuses for all parties.
Duration
Block your full business day. Most civil mediations conclude in 4–8 hours; complex commercial or malpractice matters may run longer. Henning provides refreshments and lunch throughout. Find out more about our hospitality.
Who Attends
All parties and counsel with full settlement authority must be present. Insurance adjusters must attend in person (or approved video). Corporate representatives must have authority to bind the entity, not merely to recommend.
Confidentiality
All communications are protected under O.C.G.A. § 9-11-38 and the Georgia Uniform Mediation Act. Nothing said or offered may be used in subsequent proceedings. Position statements are returned to counsel at session end upon request.
Position Statements
Submit your brief 5 business days prior. Include: case summary, liability analysis, damages overview, prior demand/offer history, and key evidentiary issues. Photographs, medical records, and expert summaries may be attached. Submissions are not exchanged between parties unless you instruct otherwise.
Settlement
When agreement is reached, counsel drafts a binding term sheet before anyone leaves. Full settlement documents are typically executed within 30 days. Henning provides a standard term sheet template on request.
Four or more parties, overlapping claims, or limited coverage? Our
team mediation approach pairs two experienced neutrals to keep every
party moving, often resolving in a single day.
Model contract language for committing parties to mediation before litigation.
Developed to reflect ADR best practices and Henning's extensive experience resolving
disputes across a wide range of industries, these sample clauses can help parties
establish a clear framework for addressing conflicts efficiently. Always have counsel
review before adoption.
Mediation then Arbitration Clause
Any controversy or claim arising out of or relating to this contract or the breach thereof, shall be submitted to mediation administered by Henning Mediation & Arbitration Service, Inc. (Henning) in accordance with its procedures. If the parties are unable to resolve their dispute in mediation, the dispute shall be settled by binding arbitration administered by Henning in accordance with its rules, and judgment upon the award rendered by the arbitrator may be entered in any court having jurisdiction thereof.
Need Custom Language?
Use our interactive ADR clause generator to build a clause for mediation,
arbitration, or both, with configurable scope, rules, and venue.
