• Remember That Mediation is Voluntary
• Attorneys Are Required to Have Clients Sign a Form Acknowledging the Scope of Confidentiality Prior to Mediation
• Identify the Decision Maker
• Mediation Confidentiality Cannot Be Impliedly Waived
• Make Certain You Have An Enforceable Agreement
• Enforce Your Settlement Under the Correct Statute
• Keeping Your Settlements Intact When There is No Written Agreement
• Be Careful Not to Lose Jurisdiction to Enforce Your Settlement Under CCP §664.6