If you fail to plan for mediation, you have planned to fail.
Yes, I consider failing to settle at mediation as a failure, though admittedly that is not exactly true, but it helps make the point I am trying to make. When I mediate a case, I have Plans A, B, C and in that order.
PLAN A is to settle the case.
PLAN B is to get each side to inform the other side of their bottom or top number (or demand). This allows each party to know exactly what it is walking away from. In medicine, we call this informed consent which means being informed of the risks, benefits, and alternatives involved in taking a certain action.
PLAN C is to have the sides exchange information, positions, and arguments so that they can better understand each other. This exchange will help future mediation sessions for that case, assuming of course that trial is not starting momentarily, though we all know a case can settle right up to moment before a jury or court makes a determination.