I typically do not ask the parties to provide opening statements to each other at the outset of the mediation.  I canvass whether this should be done with counsel prior to mediation but typically I recommend against it.

I require decision makers to be present with full authority to settle.  I strongly suggest that the parties know and agree in advance exactly who will be present from the other side.

I ask each party and their counsel to sign a mediation agreement in advance.

In advance of mediation, I ask counsel to provide me with copies of all settlement offers, pleadings and important discovery evidence if discoveries have taken place.  My role is not to weigh evidence but to challenge parties with the realistic prospects of their positions.

I schedule a brief pre-mediation call with each lawyer separately for a candid appraisal of issues that they believe to be an impediment to settlement.