Close the deal today and don't leave decisions on the table—especially when dealing with less experienced opposing counsel or pro se litigants.

When I was in law school, my mediation clinic professor and nationally known mediator, Rodney A. Max, Esq., drilled into his students the need to complete all material terms and special language before leaving the mediation. Perhaps I didn't listen well enough, because I found myself "relearning" that lesson a few months back while mediating a professional liability case.