Sometimes counties let mediators recommend and it's crucial to know which rule applies before going to mediation and court. Mediators are psychologists with the goal of getting an agreement, but even in a non-recomending county, they can have ways of telegraphing their views to judges when there is no agreement. Sort of like husband and wife telegraphing that it's time to leave a party or something. The important thing in mediation is not to come off too hostile, don't interrupt etc. As a psychologist, the mediator will observe the process more than he / she will learn from written documents. Presenting them a lot might just look obstructionist, getting in the way of the agreement. That said, a timeline is always helpful, esp. if fairly and simply prepared. Dates of marriages, separation, births, custody orders,names of shrinks and authorizations to speak to shrinks (not that they will in most cases) all look helpful to the mediator and probably are helpful. The worst thing either parent can do is talk about the past, interrupt the other or the mediator, fail to acknowledge one's tiny little faults, insult the other parent The binder is still a good idea not for the eediator but for the litigant so that important facts/views are present in his/her mind. It's always important to keep ones eyes on the ultimate goal (a good childhood for the kids) rather than the tempting goal of getting the mediator to gang up on the other parent as a bad person. It can be the most natural thing in the world to go to mediation unless the sight of the other party makes you want to revive the quarrels of the marriage. Oh, and never bring the new boyfriend or girlfriend to court. Sometimes they like to come, and that's why there's a coffee shop nearby.