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"Prepare your client"

 Since mediation involves dynamics that may be unfamiliar to your client, it is wise to prepare them BEFORE the mediation.  Make sure you explain to them the structure of the process, the role of the mediator, and perhaps a little about who you know will also be in attendance.  Take time to also explain to them your role as an advocate when the other parties or mediator are in the room.  This is important so that they understand why you say certain things to others and perhaps different things to them. Think about telling your client to only listen to you when you and they are the only ones in the room. Without this type of preparation, advocating strongly in mediation may make it more difficult for them to compromise.

Richard B. Lord
Shareholder
Upchurch Watson White & Max Mediation Group

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