Your case valuation analysis tells you only the extent of the monetary and other concessions your client is prepared to make. You also need a plan for how you will parcel out those concessions at the negotiating table. The plan should provide for tapered concessions – your largest move first with each move thereafter smaller than your last move – pointing toward your client’s settlement target. Show the other side a consistent path to your bottom line position. Without a negotiating plan it is easy to fall into bargaining reactively and emotionally, which is usually less effective.