Better preparation for your expectations. Often parties/lawyers come to the mediation expecting the other side to realize the strength &...

The power of walking away. Pretty strange that I would talk about, let alone say encouraging words, about walking away...Don't get me...

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...

It is important for the parties to be heard at mediation. However, giving everyone a joint forum to "air out" their feelings often...

The power of an apology. I know what you're thinking – (plaintiff): the apology will be insincere & defense just expects it to reduce...

I handle many "early" mediations. They often settle, but have challenges, specifically the lack of sufficient information about the other...

As you prepare for a mediation, also prepare your client for the mediation process. It can help to share with your mediator any...

Keep in mind an end-goal of your opposing counsel being your ally in the other room at mediation...Establishing a good and cooperative...

While it is necessary to include sufficient space with which to move your numbers, when the other side recognizes the reasonableness of...