Preparing for a mediation

Once you have found your mediator, the process begins.  There are pre-mediation conferences, documents to be reviewed and each side should submit documents to their mediator giving up-to-date status of the case 48 hours prior to the time of the scheduled mediation.
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

1. Have your client present at the mediation!  Available by phone is unacceptable.
2. Have every document needed to prove your case
3. Talk to your client about the goals of the mediation
4. Know your "ask" and know the bottom line the client is willing to accept to make a deal that day. 
5. Don't expect the mediator to do your job for you - it just slows everybody down.