Lawyers and mediators sometimes fail to appreciate that a mediation requires as much advance planning and consideration of strategy as a trial. Too often, lawyers (and some mediators) pick up the file a day or two in advance (at best) and wing it, relying on their advocacy skills and smarts to negotiate their way through the mediation day. This approach does not serve the needs of everyone involved. By using the following mediation countdown, everyone will come to the table prepared.

1. Develop a Timeline -

Using the tools below, if you are counsel representing a party, decide when you want the mediation, and then plot your timeline just as if it were a trial date. List all the tasks you need to do: prepare case analysis; educate clients on the mediation process and their role; and identify client positions and those of the other side. Be sure to allow for significant trial events and dates or any post-session follow-up.

Originally published on Law.com on January 21, 2015.