To enable me to prepare for the mediation I usually ask you to send me the statements of case lodged with the court, assuming proceedings have been issued, together with any core documents you think I should read. I would also like to see any offers of settlement that have already been made. If proceedings have not been issued the letter of claim and response will help me understand the issues.

If the papers do not contain everything you feel I ought to know a position statement might be helpful. This can be set out in a simple e-mail, and may be for my eyes only or you can share it with the other party to the mediation.

It is important that I get my papers a few days before the mediation to give me a chance of reading them. I would also appreciate a contact number so that I can call you before the mediation if there is anything I need to discuss with you.

There is also some preparation I would like you to do. Have you got all the information you need to make or evaluate an offer? For instance do you need an up to date valuation or costing. If the other party has not seen all the information you intend to rely on at the mediation consider producing it to them in good time so they have a chance to review it, as documents produced on the day are sometimes dismissed out of hand.

Most important of all you need to think about the range of offers that might be acceptable to you. The strengths and weaknesses of your case will obviously have an effect on the range, but there may also be some personal factors and if there are I would like to know about them early in the mediation. A mediation is your opportunity to agree an outcome that is acceptable to you, but you will not reach agreement unless you can find an outcome that is also acceptable to the other party and it may help you formulate your offers if you think about their needs and the extent to which you might be able to accommodate them.