Listen Carefully to the Mediator's Feedback

Mediation is a Safe Forum

Let the Mediator Set the Pace

Listen With Few Interruptions

Recognize the utility of private meetings (caucuses) with the mediator

Be Persuasive!

Leave the Litigators At Home

Don't Argue About Who is Right

Let the Other Side Pick the Mediator

Prepare For and Use Mediation as a Negotiating Tool

Listen to the Mediator’s Observations

Use a Negotiating Approach that Works for You

Don’t be Afraid to Walk Away (or Continue Negotiations!)

Be Principled

Prepare Your Client

Use the Mediation Statement and Opening Statement

Research, Research, Research

Be Prepared!