Stuck in your negotiation or mediation? These questions might help you move from being stuck to moving forward together.
1. How can we decide which option to choose?
2. How can we accomplish what you want?
3. What makes that solution fair?
4. How did you arrive at that idea?
5. What is the theory behind that?
6. How do other people handle that problem?
7. What would happen if you went to court?
8. Would expert opinion be of any help?
9. What is it you are trying to accomplish?
10. How have you resolved this problem before?
11. Is there another alternative you can think of?
12. Why do you think that will/won’t work?
13. What would you need to resolve this dispute?
14. What do you think your opponent wants?
From this manual [here], note the link is a pdf file.