This document provides strategies and tactics for effective mediation. It discusses selecting an appropriate mediator based on the strengths and weaknesses of the case. For example, choosing a former plaintiff's attorney if the defense case is strong. It also discusses strategic timing, noting that mediating early may yield higher settlements but allow more discovery if the defense case is strong. The document outlines tactics to use during mediation like an effective opening statement and presentation of evidence. It stresses being well-prepared and understanding the facts, law, evidence and roles. Finally, it discusses closing the mediation and factors like when to agree to reconvene or understanding if an offer is final. The overall document gives an overview of important considerations for mediation strategy and success