LISTEN TO UNDERSTAND, rather than to find fault. Whether or not you agree, always assume there may be information valuable to achieving resolution in what others say.
SPEAK TO BE UNDERSTOOD. Consider in advance how you can talk about difficult issues in constructive ways. Avoid threats, negative judgments, name calling, sarcasm. To achieve your goals through agreement, others must be willing and able to hear the important things you have to say.
GO BEYOND POSITIONS ("I’m not going!") and DISCUSS INTERESTS ("I don’t feel safe in that old truck"). When you are able to move from positions and begin to talk about the underlying interests, the potential for agreement is hugely expanded ("What if I borrow Ted’s new Volvo?").
CONSIDER OPTIONS FOR MUTUAL GAIN. There is no agreement until all parties agree; and no one will agree unless their needs are satisfied to an acceptable level. If reaching agreement is your goal, then it's beneficial to consider solutions that address interests on both sides of an issue.
DON'T GET STUCK ON A SINGLE SOLUTION. There are almost always several ways to address an issue—be creative and don’t limit yourself to just one.
BE READY TO WORK during the mediation. Achieving success in mediation requires best efforts from everybody.
BE PATIENT. Collaborative problem solving takes a little time. However, the agreements reached are often the most durable and satisfying.