Opening presentation to mediator/arbitrator actually starts at the selection of the mediator when your due diligence occurs to discover his/her background, experience, and substantive knowledge of issues relevant to the case. If possible, reviewing the mediator’s prior decisions, and using your network to ask others who had proceedings before the mediator/arbitrator about their experiences. You can learn a lot about the Mediator’s manner/style/attitude/approach to the case during the pre-hearing matter scheduling calls/zooms. Is mediator asking questions, listening to the parties, apportioning time for discussion fairly, and is disciplined in getting the matter started with details about discovery issues, motions, expert witnesses, and scheduling? I have found that the ‘decider’ reads the pleadings before the hearing starts, and your opening is the opportunity to summarize the case by prioritizing and synthesizing (narrowing) the facts and issues from your side’s perspective. Tell the essential ‘story’ of your case and leave the mediator anxious to hear more. I leave time to present ‘counter-views’ of the most critical ‘fault’s’ in the opposition’s position, but not regurgitate their side.