As a result of mediating many commercial disputes over the past five years, I have distilled certain principles that lawyers advising a party in a mediation can usefully consider in order to achieve a mediated solution, if one is possible, in the particular circumstances. They are by no means prescriptive but they cover most of the essential areas.
"Seven principles for successfully advising a party in a mediation,"
6, Article 2.
Available at: http://epublications.bond.edu.au/adr/vol1/iss6/2