To ensure a successful mediation experience for your client, it is important to spend the time and effort to fully and adequately prepare in advance. Proper preparation includes spending time with your client reviewing the facts and legal issues, including your claims, defenses strengths and weaknesses, as well as those anticipated by the other side. Analyzing the motivations and impediments to a negotiated resolution, and, analyzing your risks through â€œ BATNA - Best Alternative to a Negotiated Agreement, will allow you and your client to properly evaluate and respond to offers made during the mediation. Further, ensuring that the right individuals will participate in the mediation, or be readily available for questions, is critical. Finally, to the extent that you need to consider tax implications of any settlement, this should be done in advance. *This program will explore the top ten items each advocate should consider and address prior to the mediation to best prepare and succeed.