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Attend the preliminary conference by telephone (or in person) so that you can understand the steps involved in the mediation.
Execute a mediation agreement which contains, amongst other things, a confidentiality undertaking.
Determine who is attending the mediation.
Ensure that the people attending the mediation have authority to settle.
Ensure that each person attending the mediation (or receiving a position paper) has signed a confidentiality agreement.
Prepare your position paper. This document should be short and simple - you may need legal help for this.
Exchange any appropriate expert reports before the mediation
Ensure that you understand the key strengths and weaknesses of your case.
Ensure that your understand your settlement options
Ensure that you fully understand the process post mediation in terms of costs, risks and inconvenience.