By the time of the mediation, the mediator will have been given all the facts of the case and be ready to reach a settlement - that day - the lawyer cannot be less than fully prepared.
LIST
- Have your client present at the mediation! Available by phone is unacceptable.
- Have every document needed to prove your case
- Talk to your client about the goals of the mediation
- Know your "ask" and know the bottom line the client is willing to accept to make a deal that day.
- Don't expect the mediator to do your job for you - it just slows everybody down.