This article provides helpful instruction to litigators on some do's and don'ts for effective mediation advocacy. Do's highlighted in the article include encouraging litigators to do their homework before selecting their mediator, how litigators can help their clients and strategize with their mediator and how to effectively listen to the mediator. Don'ts include making more work for themselves or the mediator, using language with the mediator that they wouldn't tolerate in return, lying to the mediator, and assuming that what is shared with the mediator is automatically shared with the opposing party.
Riding High With Your Mediator: The Do's and Don'ts of Effective Mediation Advocacy
Allen, Tracy L. . Utah Bar Journal, Sep. 30, 2008https://arbitrationlaw.com/library/some-dos-and-donts-mediation-adocacy-dispute-resolution-journal-vol-58-no-1