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1. Never let the perfect be the enemy of the good (or great).

2. Before the Mediation, determine your best alternative to no agreement [BATNA] and worst alternative to no agreement [WATNA] at Mediation.

3. Before Mediation, evaluate your strengths, weaknesses, opportunities and threats [SWOT] under BATNA and WATNA.

4. Preserve, where possible, potential for future successful business relationships.

5. Expect and anticipate, and do not be frustrated by, impasse which is part of the Mediation process.

6. Prepare decision makers to consider input from outside counsel, in house counsel, experts, and the Mediator at Mediation.

7. Consider the perspective and legitimate goals of the adverse party.

8. Practice reciprocity in giving and receiving compromises and concessions.

9. Make a commitment to be consistent.

10. Accept the validation of social proof, people doing what they observe others to be doing.

11. Be independent from authority figures.

12. Find common ground in liking one another.

13. Understand that scarcity is a powerful motivator.

14. Embrace unity in reaching agreement.

15. Experience the empowerment of being nice.