- 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