Preparation is the main key to a successful mediation session
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This article details 10 ways to prepare: *from Bennett G. Picker
- Exercise Due Diligence in Selecting the Mediator.
- Identify and Involve Client Representatives.
- Determine Whether Information Exchanges Are Necessary.
- Prepare Arguments Supporting Legal Positions and Settlement Positions.
- Prepare a Confidential Written Statement to the Mediator in Advance of the Mediation Session.
- Prepare a Concise “Opening Statement” for the Joint Session.
- Make an Objective Litigation-Risk Assessment.
- Explore Potential for Creative Solutions.
- Develop a Negotiating Plan.
- Prepare a Draft Settlement Agreement.