Publications and Resources

Honeywell Mediation, through its principal, Dan H. Honeywell,  as author and speaker, provides online and other access to publications of Mr. Honeywell for those who wish to become more successful at Alternative Dispute Resolution, including mediation and its relationship to trial practice, arbitration, negotiation and other forms of potential resolution without trial.

Educational Blog

Since 2010, Mr. Honeywell has published numerous articles on mediation, trial practice and negotiation that are available to you, without charge and easily accessible either through this website, at tab:“Educational Blog Link” or directly, at

The most current postings can be found at the tab, “Current Blog Postings”.

For your convenience in finding a specific subject, the following is a historical Topical Index of all of Mr. Honeywell’s educational blog-articles previously published.  Once you have selected your topic, use the above noted “educational blog link’ tab to take you to the archive section, “My Prior Posts”, for the older postings of Mr. Honeywell’s ongoing blog.
I.          Introductory
I Have Always Been Passionate.
December 8, 2010
Why Mediate When Mediation is a Waste of Time?
June 12, 2011
You Might Have The Wrong Mediator If…
January 2, 2012
Become One of the Top Ten Percent of All Mediating Attorneys.
April 11, 2013
II.         Pre-Mediation Preparation
Would A Pre-Mediation Case Management Order Improve Success At Mediation?
February 2, 2011
Personal Injury Mediation: The “Surgical Recommendation Letter” Issue.
April 26, 2012
Commercial Mediation: The “Collectability” Issue, Its Uses and Proof.
June 18, 2012
Mediation Strategy: A Mediator Retained Only as a Consultant.
June 11, 2012
Predicting Your Own Mediation Outcome: Warning Flags to Read.
September 21, 2012
The Will Not To Believe – The Mediation Nightmare.
October 31, 2012
Personal Injury: Know the Details of All Insurance.
November 19, 2012
Winning or Losing…”Fagitaboutit.”
March 5, 2013
Mediation: Reserves and Settlement Authority: What You Must Know.
May 23, 2014
Mediation Tip: Start/Keep a Mediation Notebook.
July 8, 2014
Dispositive Motions and Mediation: Three Simple Tips for Greater Success.
November 29, 2014
Your All-Important Pre-Mediation Summary: Seven Other Valuable Uses!
March 23, 2015
III.        Evaluating Your Mediation Position
Rule One: Know Your Alternative(s) Should Mediation Be Unsuccessful.
December 19, 2010
Consider the Real Estate Market When Planning Your Next Mediation Negotiation.
December 22, 2010
Don’t Fall In Love With Your Position.
January 12, 2011
Proposal For Settlement And Mediation; Part I: Negotiation and Timing Goals.
February 20, 2012
Personal Injury Mediation: Relax! Not Every Case Can Be Resolved In Mediation.
February 12, 2013
Sovereign Immunity and Mediation.
May 29, 2013
Mediation Negotiation: One Reliable Method of Evaluating Personal Injury Damages.
December 18, 2013
IV.       Scheduling Mediation
The Weaker Your Position, The Earlier You Should Mediate.
December 13, 2010
Early Mediations Require Claimant/s Deep Discounting.
August 29, 2011
Sufficient Time Is Required For Success.
November 10, 2011
Timing The Scheduling Of Your Mediation.
January 28, 2012
Mediation Tip: Litigators, Use Mediation To Move Your Case!
March 23, 2012
“But They Asked For This Mediation!”
January 7, 2013
Hourly Fee Cases and Pre-Suit or Very Early Mediation: A Can’t-Miss Combo.
May 10, 2013
Early Mediation: A Reminder of the Pros and Cons!
January 13, 2014
V.        Selecting Your Mediator
Be Active In Jointly Selecting Your  Mediator.
December 31, 2010
Does (the Experience of) Your Mediator Matter?
May 2, 2011
Picking Your Mediator Should Be Like Picking Your Jury.
August 4, 2011
Fall: A Wonderful Time Of The Year To Try A New Mediator.
October 5, 2011
My Opinion: Good Mediators Lead Best From the Back of the Room.
September 30, 2014
Mediation Preparation: Start/Maintain Your Own Short List of Trusted Mediators
May 19, 2016
VI.       Mediation Procedure
Be Advised: A Major Change In The Florida Rules Of Procedure Regarding Mediation Procedure.
November 22, 2011
The 2012 Mediation Rule Changes:  A Few More Concerns.
February 3, 2012
Proposal For Settlement And Mediation: Part III – Mediating With An Unexpired Proposal For Settlement.
March 5, 2012
Florida Mediation Procedure: PLEASE, Send Your Mediator A “Courtesy Copy” of Your Certificate Of Authority.
March 30, 2012
Mediation Certificate of Authority: A Few Thoughts on Questions Being Raised
May 3, 2012
Mediation Certificate of Authority:  More Thoughts on More Questions Being Raised
May 31, 2012
Pre-Mediation Summaries: Why Bother?
July 11, 2013
Mediation Procedure Suggestion: Send Your Own Notice of Mediation.
April 4, 2014
Basic Mediation Administration: Helpful Hints to Use for a Much Smoother Ride.
December 3, 2015
VII.      Mediation Attendance
Successful Mediation Requires All Participants Attend.
March 21, 2011
“Early Bad Faith” Mediations Require The Proper Participants.
April 19, 2011
 Mediation:  Use Extreme Caution When Waiving Any Participant’s Personal Appearance
June 8, 2012
Mediation Tip: The Importance of Early Appellate Counsel Actively Participating in Appellate
October 4, 2012
Include a “Caesar Whisperer” at Your Next Mediation.
October 23, 2014
VIII.     Mediation Conference – Opening Statement
Mediation Opening Statement: Some Initial Considerations.
March 1, 2011
Consider Having Your Client(s) Speak Directly To The Other Side.
March 15, 2011
Mediation Opening Statement: More Considerations: PowerPoint.
May 16, 2011
Mediation Opening Statement: Another Consideration…A Timeline (Please!).
July 27, 2011
Mediation Opening Statement: A Required Consideration…Your Likely Verdict Form.
August 9, 2011
Body Language Control May Be Helpful.
September 14, 2011
A Radical Idea? Consider Waiving Your Opening Statement.
September 30, 2011
Mediation Opening Statement: More Considerations: More Thoughts On PowerPoint.
November 18, 2011
Mediation Opening Statement:  Organize and Shorten It For Maximum Effect
May 18, 2012
Mediation Opening Statement:  Try a Different Approach
January 31, 2013
Trial Advocacy v. Mediation Admission, Concession and Conciliation.
February 12, 2016
Mediation: One Sample for a Perfect Plaintiff’s Counsel Opening Statement?
April 15, 2016
Mediation: One Sample for a Perfect Defendant’s Counsel Opening Statement?
July 20, 2016
IX.       Mediation Conference – The Process
Consider A “Quickie”.
January 18, 2011
One Classic Mediation Success: A Perfect Storm or a Pattern to Emulate?
March 14, 2012
How to Mediate Attorney’s Fees, Part 1: Hourly Fee Contracts
July 25, 2012
Mediating the Medical Negligence Matter: Ten Major Differences, Part I: The First Five
August 3, 2012
Mediating the Medical Negligence Matter: Ten Major Differences, Part II: The Next Five
August 14, 2012
Early Bad Faith Mediation: New Techniques to Consider?
September 13, 2012
Mediation Tip: Avoid Caucusing Within Glass Walls
December 16, 2012
Mediation Parties: Get the Most Out of Your Apology!
June 11, 2013
Mediation Tip: Always Avoid Your Opposition During Formal Mediation.
December 29, 2014
Does State Court Procedural Laxity Contribute to State Court Mediation Failure?
January 8, 2016
Mediation: A Great Place for a Return to Professionalism and Civility
September 29, 2016
X.       Mediation Conference – Negotiation
Don’t Run Out of Time.
January 25, 2011
Putting The “For Sale” Price On Your Horse.
January 31, 2011
Work On Your Personal Credibility To Improve Your Negotiation Success.
March 9, 2011.
Learn To Become An Active Listener.
April 13, 2011
Leave Your Guns At Home.
August 15, 2011
Mediation Negotiation 101.
July 4, 2011
Know Your Pecking Order In Multiple Party Matters.
June 21, 2011
Bracket Offers: The Good, The Bad, The Ugly.
October 24, 2011
Is “Fear Of Failure” Ruining Your Negotiations?
December 10, 2011
Learning Mediation Negotiation Technique: First, Personal and Professional Credibility.
August 23, 2012
Mediation Negotiation Technique: Create a Negotiation Plan.
October 16, 2012
Managing Expectations – But, by the Defense?
January 22, 2013
Incremental Offer Negotiation in Mediation: More to It Than Meets the Eye.
April 3, 2013
Mediation Negotiation: The Importance of the Drama.
October 24, 2013
Mediation Negotiation: Plan a Soft Landing.
November 20, 2013
Personal Injury Mediation: A Disturbing Trend or A New Flawed Tactic?
March 12, 2014
How to Achieve Mediation Resolution When Opposing Counsel Actively Resists Settlement.
April 29, 2015
Negotiating “Policy Limits” Matters in Personal Injury Mediation.
June 4, 2015
Mediation Negotiation: The Defense’s Opening Offer (assuming resolution is your goal).
September 6, 2015
Mediation Negotiation: Increase Your Pace for Greater Success.
March 10, 2016
The “Principled” Demand or Counter-Offer: A Better Method of Negotiation
June 7, 2016
Mediation Negotiation: Want a Home Run? First, Find the Ballpark!
October 27, 2016
Personal Injury Mediation: Success for the Defense? Get Your Real Money on the Table, Early!
November 17, 2016
XI.        Duties of Your Mediator
A Key Mediator Duty: Maximize The Effectiveness Of Negotiation.
April 25, 2011
A Role Of The Mediator?: Assisting Participants To Be Ready To Mediate.
July 23, 2011
(Berman) Make Your Mediator Work Harder.
August 22, 2011
Your Mediator: These Days, Best Considered a Farmer?
October 21, 2015
XII.       Mediation Strategies – Special Issues
Global Settlement Mediation For Multiple Claimants And Limited Insurance.
July 15, 2011
Plaintiff’s Attorneys Must Use Caution When Negotiating Fee Claims Concurrent With Client’s Interests.
October 13, 2011
Mediating With Prior Confidential Partial Settlements.
January 10, 2012
A Radical Consideration:   Consider A Voluntary Change of Counsel When Mediation Fails.
February 9, 2012
Proposal For Settlement And Mediation: Part II: More Tactical Suggestions.
February 28, 2012
How To End Your Unsuccessful Mediation and Still Achieve Resolution.
April 13, 2012
Mediation Impasse: Failure or Opportunity?
June 26, 2012
Your Holiday Gift: Stress-Free Mediation.
December 24, 2012
Personal Injury, Letters of Protection and Mediation.
February 21, 2013
Mediation Tip: Always Perform Your Post-Mediation Action Review.
March 19, 2013
Personal Injury, Professional Medical Expert Witness and Mediation.
April 29, 2013
Personal Injury Mediation: Another Foreseeable Roadblock: Client Cash Advances.
October 8, 2013
Mediating/Negotiating With a “Sovereign” Defendant: Six Differences.
June 26, 2014
Proposal for Settlement and Mediation: Part IV, Mediating With an Expired Proposal for Settlement.
July 24, 2015
XIII.      Mediation Settlement Agreement
Personal Injury Practice? Start Your MSA (Medicare Set Aside) Notebook Now!
February 14, 2011
MSA: Additional Thoughts For Your Mediation Preparation.
June 27, 2011
 Your MSA Notebook: Release Language Ethics: Plaintiff’s Lawyers May Not Personally Indemnify; Defendant’s Lawyers May Not Request or Require Personal Indemnification.
November 30, 2011
Mediation Settlement Agreements: What You Should Know.
January 18, 2012
A Growing Mediation Settlement Agreement Issue: Confidentiality Language.
August 14, 2014
XIV.     Arbitration
Mediators as Arbitrators?
August 1, 2013
Nursing Home Arbitration: The Headache of Obtaining Your “Deciding” Arbitrator.
August 23, 2013
Arbitration: Unilateral Steps to Manage Timely Selecting Your “Deciding” Arbitrator.
August 30, 2013
Florida’s Revised Arbitration Code: Better Review Today!
February 27, 2015
XV.      Trial Practice
Post-Mediation Tunnel Vision: Caution, It Can Hurt Your Client!
February 11, 2014
XVI.     Personal
A Dog Named Bear.
February 10, 2011
Memorial Day for Me.  Memorial Day for You?
May 24, 2012
Post Election Day: It is time to move on…but together for a change.
November 7, 2012
Honor the Jury. All Jurors, All Juries, All Verdicts.
July 19, 2013
Lessons Learned From Geese.
January 1, 2014

Other Publications:
Why Mediation Doesn’t Work   (Draft, pending publication in periodical format)
Mr. Honeywell is a sought-after speaker on the subject of mediation, negotiation and pre-trial and trial procedure.
The following is an index of speeches recently presented or pending presentation on relevant subjects.
Mediation Negotiation- A Crash Course  (2012)  
Mediation Negotiation- A Short Course    (Pending)
How To Mediate Better Than Your Boss    (2011)
Black Hat/White Hat and Grey Matter In Mediation (w/David Henry) (2011)
10 Easy Secrets To Success In Mediation   (2010)
Expectations-Reasonable and Unreasonable   (Pending)
Is Mediation Killing The Art Of Negotiation?   (Draft)
Mr. Honeywell provides a number of informational handouts for his mediations and seminars. A copy may be obtained upon request. The following is an index of those handouts presently available:
A Few Questions To Consider For Greater Success In Your Mediation (2 Pages) (2009)
Suggestions For Greater Success In Debt Mediation  (2009)
Information For “Pro Se” (Unrepresented) Mediation Participants (4 Pages) (2009)
10 Easy Secrets To Success In Mediation By Plaintiff’s Attorneys  (2010)
Trial Practice
Cross Examination Organizational Outline for Beginners (3 Pages) (2012)