(I found this list online and thought it may be of some use in your practice whether it be as a litigator or mediator.)

  1. So I understand your position…
  2. I think we can agree that…
  3. I understand where you are coming from,
  4. Can you clarify what you mean?
  5. I appreciate your input.
  6. Let’s try a different approach.
  7. I am committed to make this work.
  8. Let’s aim for a common ground.
  9. Can we revisit this topic after some reflection?
  10. I am open to feedback.
  11. Help me understand your perspective.
  12. I want to make this a win-win.
  13. Let’s work together to reach an agreement.