1. Overview of Florida Statutes and Procedures re: Mediation

2. Case Law Update on recent decisions regarding mediation, including a discussion of potential problems with suggested solutions in Mediation.

3. Ethical Considerations in Mediation - confidentiality, privilege and disclosure.

4. Mediation tactics and techniques:
   • Preparation for Mediation - counsel and client(s)
   • Initial Presentation tips and techniques
   • Negotiation strategies and techniques

5. Selection of the Mediator
   • Subject matter knowledge
   • Different "styles" for different cases/clients
   • "Orchestrator"/"Facilitator"

Allene D. Nicholson, Esq.

(As presented to the Dade County Defense Bar, Miami, Florida 1995 - MEDIATION FROM THE DEFENSE PERSPECTIVE)

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