By Richard A. Mann, Mann Law PC
Looking for a quick list of tips and tricks to help make you succeed in your next mediation? Start here!
- Make sure you and your client are available the entire day on the date of mediation.
- Prepare your client to have realistic expectations.
- Prepare the mediator by providing him or her in advance with all facts the judge would need to make a decision. If there's not enough time to prepare a formal written statement, call or email the mediator.
- Prepare a mediation statement and distinguish between facts everyone involved knows and your confidential facts or strategy.
- Supply the mediator with a Word or WordPerfect document setting forth a global settlement covering all issues including documents the judge needs to sign to finalize your case and additionally, if necessary, release documents, new contracts and documents to make transfers.
- Have all discovery completed and exchanged.
- Have all documents showing values of bills, debts, and assets.
- Contact third parties, when necessary, to see if you can compromise or lower what they will take i.e. credit card companies, medical providers, etc.
- Make a settlement offer well in advance of mediation.
- Bring all the above to the mediation. Do all of the above at least 48 hours before mediation.
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