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Tips for a Successful Mediation

· Prepare, prepare, prepare. Although mediation is not a formal proceeding such as a trial or hearing, participants should know their claims or defenses and their evidence before the joint session of mediation. If you present your arguments well (and present them tactfully), you may convince your opponent that settlement will be their best option.

· Bring any valuable documents to the mediation. While there is no need to produce any such evidence, Mr. Banov may find it valuable to remind the other side of any good exhibits you present.

· Bring any valuable documents to the mediation. While there is no need to produce any such evidence, Mr. Banov may find it valuable to remind the other side of any good exhibits you present.

· Be polite and tactful. Mediation is war by other means. Leave your litigation weapons behind you. You can always use them in your court case or EEOC case. Honey works better than vinegar!

· Be flexible with your demands. Take-it-or-leave it demands or offers are hardly ever successful. At the end of each private conference with a party in mediation, Mr. Banov advises them, "Be flexible."

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