I find the old adage "where there's a will, there's a way" applies generally in life and, in particular, in mediations. Indeed, I have yet to find a situation where two parties acting in good faith and wanting to reach a deal could not do so. With respect to mediations, I would even venture to say that, when one doesn't lead to a settlement, it is because of one or both parties' state of mind and seldom due to the subject matter of the dispute itself. And thus, the truly complex and challenging mediations will often revolve around parties who, for one reason or another, are ill-equipped to settle.