Here are 5 suggestions based on what I see parties succeed with at mediation:
1. Prepare a valuation range based on settling “today” versus post probable cause, MSJ, trial, etc., or other things in which no one (including you) has yet invested resources.
2. Make proposals that are based on components you can break down, easily explain and substantiate.
3. Bring research (case law) that supports and challenges your position – be they judgments or a range of awards. Be sure they relate factually.
4. Be the first to address weaknesses in your position and not just strengths, and incorporate both in the position you take.
5. Have decision makers with full settlement authority at the table.
With these, you should be well poised to attain resolution.