I handle many "early" mediations. They often settle, but have challenges, specifically the lack of sufficient information about the other side's case, & insufficient "litigation pain"inflicted. To improve chances of settlement, it helps to take that risk and share information with the other side: documents that will be produced anyway; documents that support your position; perhaps (w/ caveat) opening numbers or settlement ranges; briefs (you can send a separate short "confide

As you prepare for a mediation, also prepare your client for the mediation process. It can help to share with your mediator any challenges you may have with your client, enlist the mediator's help. Doing so does not weaken your position, but does allow the mediator the opportunity to make the process easier for your client, which helps achieve a successful resolution.