A divorcing couple seated together across a conference table from the mediator, a blank sheet and a pen in front of each of them
Divorce mediation · Jackson, and statewide in Wyoming by video
Divorce mediation · Jackson Hole, and statewide in Wyoming by video

Divorce mediation, with a trial lawyer as the neutral.

Both of you, one mediator, and a complete court-ready agreement in four to six sessions. The first session is $500. After it I quote one flat fee for the whole mediation, and nobody watches a clock again. What you are paying for is thirty years of watching judges decide the same questions you are about to settle: I tell both of you, in the same words, what a Wyoming court would likely do, and then you decide instead of the court. I am not either spouse's lawyer here, and I never will be.

Start
Both names on one form, or one call with both of you on the line
Request a first session
Call
In person at 40 E Simpson Ave, Jackson, or by video anywhere in Wyoming · Text
Do not
Call me alone about the case.
If one spouse talks to me about the marriage before the other is in the room, I cannot be the mediator. The request has to come from both of you.

Three things to know before you call.

$500, then one number.

The first session is $500, paid when it is booked, about ninety minutes, both spouses present. At its end I quote a single flat fee for the entire mediation: sessions, worksheets, after-tax analysis, drafting, signing. No hourly billing. You decide how to split it.

Never your lawyer.

A mediator who might later represent one of you is not a neutral. From the day conflicts clear I am disqualified from representing either spouse in this matter, whether or not the mediation succeeds. Both of you know it on day one, and it changes how you talk.

A finished agreement.

You leave with a complete marital settlement agreement, a parenting plan in the "well defined terms" the custody statute requires (W.S. § 20-2-201), and a child-support worksheet, each reviewed by your own lawyer, signed, and filed for a decree on the papers.

How it works, start to finish.

Nine steps, one to two months. The order is deliberate. Conflicts clear before anyone says anything substantive. Disclosure comes before negotiation, because a number agreed without the statements behind it is not an agreement. Children come before money, because money is easier once the children are settled, and the reverse order turns a parenting schedule into currency. And each of you has your own lawyer read the finished agreement before you sign it, because the review is what makes it binding, not a formality I am tolerating.

Sessions are in my office two blocks from the Teton County courthouse, or by video from Cheyenne, Casper, Sheridan, Pinedale or wherever in Wyoming you are. Most Jackson couples I mediate have one spouse already living somewhere else, and video is how those cases get done.

In Teton County. Judge Owens, the county's only district judge, orders mediation whenever either party asks for it, so most contested cases here end up in a mediator's office anyway. The difference with this page is that you get there first, before the scheduling order, the discovery and the expert fees. When a pending case settles, her chambers wants to hear promptly, with an estimated date for the dismissal or decree papers, and the proposed decree goes in through the Clerk of District Court.

Nine stepsOne to two months
  • 01You contact me together: the joint form below, or one call with both of you on the line
  • 02My office clears conflicts on both names. From that moment I am disqualified from representing either of you
  • 03First session: $500, paid when booked, about ninety minutes, both of you present. I hear what each of you is worried about and explain the process and the law
  • 04I quote one flat fee for the whole mediation, and the clock stops
  • 05You sign an agreement to mediate and exchange sworn financial affidavits and the statements behind them (§ 20-2-308; W.R.C.P. 26(a)(1.1))
  • 06Four to six joint sessions over one to two months: the children first, then the money
  • 07I draft the complete settlement agreement, parenting plan and child-support worksheet
  • 08Each spouse's own lawyer reviews the agreement. Required, not optional
  • 09Signing session, filing, and a decree, usually entered on the papers no sooner than twenty days after filing (§ 20-2-108)
The mediator taking notes while a husband and wife read a draft term across the conference table
Both spouses in the room, one set of notes, and every number explained to both of you in the same words

The rules I work under.

RuleWhat it means for youWhere it comes from
You approach me togetherThe first contact is a joint form or one call with both spouses on the line. If one of you calls alone and talks about the case, I cannot mediate it.Neutrality
I never represent either of youOnce I have served as your mediator I am disqualified from representing either spouse in this matter, whether or not we finish, forever.Wyo. R. Prof. Conduct 1.12, 2.4
I am not your lawyerI explain Wyoming law to both of you in the same words. What to accept is advice, and advice comes from the lawyer each of you hires to review the agreement.Wyo. R. Prof. Conduct 2.4(b)
Confidential by statuteWhat is said in mediation is confidential and privileged; I cannot be made to testify about it. Exceptions: written consent of both, a contemplated future crime or harmful act, suspected child abuse, information discoverable anyway, enforcement of the signed agreement.W.S. §§ 1-43-102, -103
Full disclosure, or we stopSworn financial affidavits and the Rule 26 documents are exchanged before any negotiation. An omission that surfaces later ends the mediation that day.W.S. § 20-2-308; W.R.C.P. 26(a)(1.1)
No side conversationsI meet with one of you alone only at my own discretion, and only when both of you know it is happening. Nothing is decided in a caucus.Neutrality
Not where there is violence or abuseMy office screens at intake. Where there are allegations of domestic violence or abuse I decline the mediation and refer each of you to counsel.Office policy
Your own lawyer reviews before signingEach spouse's independent counsel reads the complete agreement before the signing session. I will not hold a signing without both reviews.Wyo. R. Prof. Conduct 2.4

Once signed and incorporated into the decree, the agreement is a court order: the court reviews the children's terms for their best interests and the financial terms for fairness, every support order must state the presumptive amount from the tables (§ 20-2-307), and the decree is enforced by contempt like any other.

What we resolve, in order.

  1. The parenting plan. Legal custody and how decisions get made; the schedule in overnights, holidays, summers, ski weeks and exchanges; communication between you; travel; the right of first refusal; and how the plan changes as the children get older. Drafted in the well defined terms the court requires. See parenting schedules and custody.
  2. Child support. Both net incomes, including seasonal and guiding pay, the statute's tables (W.S. § 20-2-304), the overnight count for shared custody, day care and extraordinary expenses, health insurance, and who claims the children on the return. The worksheet runs on the screen in front of you; the calculator on this site is the same arithmetic.
  3. The house. Who keeps it or whether it sells; a buyout priced after tax and after the cost of a sale, not off a Zillow number; a refinance deadline with a consequence; the deed and the note. In Jackson the house is usually the biggest asset in the case, and deed-restricted or employee housing has rules of its own. See keeping the house.
  4. Retirement, investments and debts. 401(k)s, IRAs, pensions and the Wyoming Retirement System, with the QDRO or plan order drafted rather than promised; premarital and inherited shares weighed as the statute weighs them (W.S. § 20-2-114); tax character of each account; debts assigned to the assets they financed.
  5. The business or practice. An agreed value or a jointly retained appraiser; a buyout secured by a note; and one income figure for the owner that is consistent with the support numbers, so nobody is paid twice on the same dollar. I have built, run and sold companies, and I can explain the owner's numbers to the spouse who never saw them without a valuation war.
  6. Alimony. Wyoming has no formula. The statute gives the court discretion, with regard to need and ability to pay (W.S. § 20-2-114), and I tell both of you what that discretion tends to produce in cases like yours. Amount, duration, whether it can be modified later, its after-tax effect, and the alternatives: a larger share of property, or a lump sum. See alimony.
  7. Taxes, fees and the loose ends. Filing status for the year of the decree, who claims the children, the last joint return and its liabilities, carryforwards, health and life insurance, a former name, and the timing of any sale. The Georgetown tax LL.M. earns its keep here: every number on the sheet is priced by what each of you keeps.
Ready to sit down together? The first session is $500, booked for both of you at once.
In person in Jackson or by video anywhere in Wyoming. The request has to come from both spouses.
Two people reviewing a term sheet across a table
The division, priced after tax, before anyone signs

What you leave with.

The documents. A marital settlement agreement that names every asset and debt, states alimony or its waiver, allocates fees and taxes, and spells out the mechanics of each transfer with dates. A parenting plan that stands on its own. A child-support worksheet showing the presumptive amount. And the transfer papers the agreement calls for: the deed, the retirement order, the income-withholding order where one is wanted.
Complete, not a term sheet.
The independent review. Each of you takes the complete agreement to a lawyer of your own, who reads it with one client's interests in mind. The review usually takes an hour or two and produces clarifications, which I make. I will not hold a signing session until both reviews are done. That review is what turns a mediated document into one a court will hold you to.
Your lawyer, your interests, an hour or two.
The signing, and the court. You sign together. Wyoming has no joint petition, so one spouse files the complaint with the agreement attached, the other accepts service and stipulates, and the court is asked to enter the decree on the papers. The court reviews the children's terms for their best interests and the financial terms for fairness. The decree cannot be entered sooner than twenty days after filing (W.S. § 20-2-108), and in an agreed case it usually is entered without a hearing.
Filed, and a decree, usually without a hearing.
If we do not finish. You keep a signed memorandum of the issues you did resolve, which the court can approve as a stipulation. The open issues go to each spouse's own lawyer or to the court. Everything said in the sessions stays confidential under the statute, and I remain disqualified from representing either of you. The time was not wasted: a case with four issues settled and one open is a very different case from one with five.
The settled terms survive. The rest goes to counsel.
A stack of decree pages and a calculator on a desk
A complete agreement, drafted to be filed and to be enforced

Fees.

ItemAmountWhat it coversHow it is paid
First session$500 flatAbout ninety minutes, both of you present. I hear what each of you is worried about, explain the process and the Wyoming law that applies to your case, screen for whether mediation fits, and quote the fee for the whole mediation. If you decide not to go on, this is the only fee.By card when the session is booked, by either or both of you.
The mediationOne flat fee, quoted at the first sessionEvery joint session, any individual meetings at my discretion, the child-support worksheet, the after-tax analysis, the drafting of the complete settlement agreement and parenting plan, and the signing session. No hourly billing.Split as you agree; most couples split it equally. Paid before the sessions begin.
Not includedVariesThe lawyer each of you hires to review the agreement before signing; any appraiser, accountant or other expert you retain jointly; the court's filing fee.Paid directly to those providers.

I quote the flat fee after the first session rather than on this page because the work varies. Two incomes, a parenting plan and a house is one mediation; a business, a pension, a trust and an alimony dispute is another, and nobody should pay for the second when they have the first.

Already represented? I also mediate for counsel.

If your divorce is already filed and each of you has a lawyer, I mediate those cases too, and they are often the fastest ones. The lawyers attend. I work with counsel on each side, in joint session and in separate rooms as the case needs, and the agreement that comes out of it is drafted with them rather than for a later independent review. Where the court has ordered mediation, I sign whatever certificate of completion the scheduling order calls for.

The structure is the same: a first session, then one flat fee for the rest, quoted per case once I know what is in it. Counsel on either side can contact my office to check conflicts and set it up; the joint-contact rule for unrepresented spouses does not apply when each of you already has a lawyer, because the lawyers are the ones talking to me. What I bring to a represented case is the same thing I bring to an unrepresented one: thirty years of watching judges decide the questions the two sides are arguing about, said out loud to both sides in the same words.

With counselPending cases
  • 01Either lawyer contacts my office; conflicts are run on both parties and both firms
  • 02A first session, with the fee for it quoted for the case; counsel and parties attend, in Jackson or by video
  • 03One flat fee for the mediation, quoted after the first session; split by agreement of the parties
  • 04Joint sessions and caucuses with counsel present, in whatever order the issues need
  • 05The agreement drafted with counsel; the parenting plan and support worksheet in the court's form
  • 06Certificate of mediation for the court's scheduling order; the stipulated decree filed by counsel
A husband and wife at a conference table, each working through their own notes between sessions
Between sessions, each of you does the homework: the statements, the budget, the calendar

Why a trial lawyer as your mediator.

  1. Thirty years of trial work, seventy-plus bench trials. Every proposal in the room is tested against what a judge actually does with it, not against what one spouse hopes. A mediator who has never tried a case can only guess at the alternative to settling. I do not have to guess.
  2. I have watched hundreds of judges make the same rulings. Thirty years in courtrooms, and a stint as a judge pro tem in Los Angeles, is an education in what persuades a judge and what does not. Mediation lets both of you hear that without the robe, before you have spent the money to find out.
  3. Every number is priced after tax. I hold a Georgetown LL.M. in Taxation. The house, the retirement accounts, the business and alimony are each priced by what the spouse who receives it actually keeps, so the division is fair in fact and not just on a spreadsheet.
  4. I have owned businesses. I have built, run and sold companies. I understand what an owner's income is and what a business is worth, and I can explain both to the spouse who never saw the books without an appraisal fight.
  5. Neutral by structure, not by promise. The rules bar me from ever representing either of you in this matter, and nothing said in the room is preparation for a later hearing. Both of you know that on day one, and it changes the conversation.
  6. A finished agreement, not a term sheet. You leave with a complete, legally binding settlement agreement and parenting plan, reviewed by your own lawyers, ready to file and ready to enforce. Most couples finish in four to six sessions over one to two months. Admitted in Wyoming, Colorado, California, the District of Columbia and Texas.

Who it is for, and what people get wrong.

When mediation fits, when it does not, mediation against a lawyer of your own, and what I tell every couple before the first session

Mediation fits when

Both of you want the marriage to end fairly and would rather decide the terms than have them decided for you. Both of you can sit in a room, or on a screen, and talk. Both of you will disclose everything and expect the same back. You want the children's arrangements worked out by their parents rather than by a guardian ad litem and a judge. You want the estate priced after tax by someone who knows what a court would do with it. And you want it over in months, privately, with one professional in the room instead of two litigation teams.

Mediation does not fit when

There are allegations of domestic violence or abuse. One of you will not disclose, or has already hidden or moved assets. One of you is using the process to buy time or to see the other side's cards. One of you cannot decide freely, for any reason. Either of you has already consulted me about this divorce. Or either of you wants a lawyer in the room advocating for you alone; that is a different service, and the divorce page describes it.

Mediation or a lawyer of your own?

In mediation the two of you decide, with the law explained to both of you equally, and the product is a complete agreement filed for a decree on the papers, usually within a few months. In litigation a judge decides after a trial unless the lawyers settle first, which in Teton County usually happens at a court-ordered mediation anyway, after discovery under Rule 26, subpoenas, depositions and, if custody is contested, the guardian ad litem Judge Owens requires. Litigation is the right answer when assets are hidden, when there has been abuse, when one spouse will not engage, or when a real legal question needs a ruling. The cost comparison is the obvious one: a first session and one flat fee against two hourly bills plus the experts. The privacy comparison is starker: mediation sessions are confidential by statute and never filed; a trial is a public hearing on a public record. And afterward, a mediator is disqualified from either spouse, while a lawyer of your own can stay on for enforcement and modification. The mediation-or-trial page goes further.

Six things people get wrong

That the mediator splits the difference: I anchor to what a court would do, not to the midpoint between two opening positions. That you can each hire me if the mediation fails: you cannot, whether or not it fails. That mediation is only for couples who already agree: it is for couples who want to agree, and the disagreements are resolved one issue at a time. That what you say can be used against you later: it cannot, by statute, and the only thing that leaves the room is the signed agreement. That you do not need lawyers if you mediate: each of you needs one for the review before signing, and not during the sessions, because I am neutral. That it takes years: four to six sessions, one to two months, and the twenty-day minimum is usually behind you by the time the agreement is ready to file.

What I tell every couple before the first session

Contact me together, or not at all. Come wanting an agreement more than a win; the process fails for a spouse who is stalling or scouting. Disclose everything the first time, because an omission found later ends the mediation and an omission found after the decree can reopen it. Bring questions, not positions: the first session is about what each of you is worried about, and the positions, if they ever come, come later. Plan on your own lawyer reading the agreement before you sign; that is what makes it binding. And expect directness. If one of you asks for something no Wyoming court would order, I will say so, to both of you, in the room.

The questions couples ask about mediation.

How do we get started?
Together. Send the joint form at the bottom of this page, or call (307) 300-2496 with both of you on the line. My office runs a conflicts check on both names, then calls you both at once to book the first session, in person in Jackson or by video from anywhere in Wyoming. I do not discuss the case with one spouse before the other is in the room, so if you reach me alone and start telling me about your marriage, I will stop you. That rule is what lets the other spouse trust that I am nobody's lawyer here, and it is the one rule I cannot bend.
Can you represent one of us if the mediation doesn't work?
No, and not because I am being difficult. The Wyoming Rules of Professional Conduct bar a lawyer who served as a mediator from representing either party in the same matter afterward, and I would decline even if they did not: a mediator who might later be one spouse's advocate is not a neutral, and both of you would negotiate differently if you thought I was auditioning. If the mediation ends without a full agreement, you keep the terms you did settle, everything said in the sessions stays confidential, and each of you hires your own lawyer for the rest. I will give either of you names.
What does it cost?
The first session is $500, paid when it is booked, and both of you attend. At the end of that session I quote one flat fee for the whole mediation: every joint session, any individual meetings, the child-support worksheet, the after-tax analysis, and the drafting of the complete settlement agreement and parenting plan. There is no hourly billing after that number. How you split it is your decision; most couples split it equally, some split it in proportion to income. Not included: the lawyer each of you hires to review the agreement before signing, any appraiser or accountant you retain jointly, and the court's filing fee.
How long does it take?
Four to six sessions over one to two months is typical. A case that needs a business valuation or a home appraisal waits for the appraiser, not for me. Wyoming's statute says a decree cannot be entered less than twenty days after the complaint is filed (W.S. § 20-2-108), which in practice is never the thing holding a mediated case up: by the time the agreement is signed and reviewed, filed with the complaint and an acceptance of service, the twenty days have usually run and the decree can be entered on the papers.
Do we have to have filed for divorce first?
No. Most couples I mediate have filed nothing. Wyoming does not have a joint petition, so when the agreement is signed one spouse files the complaint, the other signs an acceptance of service and an answer or a stipulation, the agreement and parenting plan are attached, and the court is asked to enter the decree on the papers. That is the quietest route through the courthouse there is. A case that is already pending can be mediated too, with or without lawyers on each side; if lawyers are involved, see the section on this page about mediating for counsel.
Is it confidential?
Yes, by statute. Wyoming's mediation act makes every communication in the mediation confidential, gives each of you a privilege to refuse to disclose it and to stop every other participant, me included, from disclosing it (W.S. §§ 1-43-102, 1-43-103), and I may claim that privilege on your behalf. The exceptions are narrow: both of you consent in writing, a communication contemplates a future crime or harmful act, a communication indicates a child has been abused, the information was discoverable anyway, or one of you asks a court to enforce the mediated agreement. The signed agreement itself is not confidential. It is filed with the court, which is the point of it.
What if my spouse is hiding money?
Then mediation is the wrong tool, and I will say so. Before we negotiate anything, both of you sign a written commitment to full disclosure and exchange sworn financial affidavits with the statements behind them, the same material the court requires in a filed case (W.S. § 20-2-308; W.R.C.P. 26(a)(1.1)). If an account, a debt or an interest surfaces mid-mediation that should have been disclosed at the start, the mediation ends that day. There is no advantage in hiding anyway: a settlement built on a material omission can be reopened, and the hidden-assets page describes what that looks like from the other side.
Is mediation appropriate if there has been domestic violence?
No. Mediation requires two people who can each say no, and a spouse who is afraid cannot. My office screens for it at intake, and where there are allegations of domestic violence or abuse I decline the mediation and refer each spouse to counsel. That is not a judgment about who is telling the truth; it is a recognition that the process does not work under those conditions. The domestic violence and divorce page explains protection orders and what a contested case looks like, and the criminal-defense page covers the other side.
What happens to the children's issues?
They come first, before a dollar is discussed. Legal custody and how decisions get made, the physical schedule counted in overnights, holidays, summers and ski weeks, the exchange points, how you will communicate, travel, the right of first refusal, and child support from the statute's tables (W.S. § 20-2-304) with the worksheet on the screen in front of you. Money is easier once the children are settled, and the other order of business tends to turn the children into bargaining chips. The parenting plan is drafted in the "well defined terms" the custody statute demands (W.S. § 20-2-201), so a court can enforce it.
What do we get at the end?
A complete, signed marital settlement agreement covering every asset, every debt, alimony if any, and who pays which fees and taxes; a parenting plan that stands on its own; and a child-support worksheet that shows the presumptive amount the way the statute requires (W.S. § 20-2-307). Each of you has your own lawyer review it, we hold a signing session, the papers are filed, and the court reviews the children's terms for their best interests and the financial terms for fairness. In an agreed case the decree is usually entered on the papers without a hearing, and the agreement becomes an order the court enforces by contempt.

Request a first session, together.

Request a first session, together.

Both names, both numbers. My office runs conflicts on both of you and calls you both at once to book the $500 first session.

Spouse one
Spouse two
About the case

Sending this form does not create an attorney-client relationship with either of you, and nothing in it is confidential until conflicts are cleared and an agreement to mediate is signed, so keep it general. By sending, you both agree we may reply to both of you by phone, email or text, and to the Terms and Privacy Policy.

One form, both of you. My office runs conflicts on both names and calls you both at once, usually the same business day, to book the first session: $500, about ninety minutes, in person in Jackson or by video from anywhere in Wyoming.

If a form is awkward, call (307) 300-2496 with both of you on the line, or have one of you text and the other confirm. What I cannot do is take the first call from one spouse alone about the substance of the case. If that has already happened, say so on the form and I will give you the names of other mediators.

Lawyers setting up a mediation in a pending case can contact my office directly; the joint-contact rule is for unrepresented spouses.