MEDIATION AND POST-ELECTION LITIGATION outsider to help educate the judiciary and state election administration about process decisions. He explains: In a recount, the deciding body is inundated by partisanship. If a neutral mediator could narrow the set of disputes that come before the deciding body by working with the parties to eliminate the outliers, the efficiency of the process would be greatly enhanced. 106 Good election attorneys are always thinking two or three moves ahead. Adjudicatory bodies therefore are unable to get input on process matters from attorneys in recounts without also getting a large dollop of partisan maneuvering. Mediators could help educate the judiciary not about which side has the better argument, but about process intricacies and decisions that the adjudicatory body must address in order to arrive at a fair and comprehensive process.I07 Election attorneys will not be fans of the idea. Even still, reigning in the adversarial process in this context might be an important step forward. Before moving on to examine a case study, an additional mediation model bears mention. One of the initial process questions mediators must confront is whether to "co-mediate." Co-mediation refers to the common practice of two mediators working together as a team to mediate a dispute. 108 The benefits of co-mediation are multiple. Most of the advantages of comediation are practical. The co-mediation model provides another set of eyes and ears to help resolve a dispute. For example, while one mediator is talking, the other can be attentive to verbal and non-verbal cues from the parties. Many mediators also prefer the co-mediation model on the theory that two minds are better than one. When one mediator might be stuck, the other might have ideas about how to proceed. A final practical benefit of comediation relates to strategic pairing. For example, a less experienced mediator might be paired with a more experienced mediator for training purposes. Mediators with divergent backgrounds or approaches might also be paired to enhance their ability to handle a complex dispute. 106 Telephone interview with the Hon. Paul H. Anderson, Associate Justice, Minnesota Supreme Court (May 27, 2011). 107 Note that any mediator interaction with the court, even if solely educative in purpose, should be handled thoughtfully. A structure in which a mediator is perceived as "reporting back" to the court may adversely impact mediator neutrality. Telephone Interview with Howard Bellman (August 15, 2011). lOS Lee A. Rosengard, Learning from Law Firms: Using Co-Mediation to Train New Mediators, 59 DISP. RESOL. J. 16, 18 (2004). 351 HeinOnline -- 27 Ohio St. J. on Disp. Resol. 351 2012