Not all mediation settlements are as simple as defendant writes a check and the parties exchange releases. Even terms of payment – timing, security, default remedies – can be contentious. A mediating party focuses on what it needs to receive but must also consider what it is willing to give to get it. Your mediator can advise you about what the other party needs to receive as to type and amount of consideration. Unless their needs are met there can be no settlement. So focus on their needs as well as your own and bait the hook to suit the fish.