As stated, many agreements are often capable of resolution by way of early negotiation. Also, it may be appropriate for the parties to consider a referral to mediation whereby an independent mediator would meet with both parties to try and promote an agreement or narrow the issues between the parties. The outcome of mediation is not binding upon the parties and after mediation both will be advised to see solicitors to consider what was agreed at mediation, and if they are still prepared to proceed on that basis the solicitors will be instructed to make the agreement binding.