I recommend pre-mediation calls with the mediator. Each mediator's style is different; In my cases, we pre-set calls in advance of the mediation; it is helpful to receive briefs before that call, but it is still useful even without briefs. The pre-mediation conference (“PMC”) is a good opportunity to speak with the attorneys outside the presence of their client, for the attorney to share strengths & weaknesses, obstacles to settlement, client challenges; presence of proper pe