When preparing for mediation, be sure to itemize your items of damage.  Even assuming that the law is on your side, you still need to prove damages.  Come prepared to discuss the items of damage, how they are calculated and any needed proof of causation.  In an accounting, the numbers should be prepared in advance so that the parties can discuss them intelligently during the mediation.  The brief should itemize these damages. Sometimes, parties are not prepared and the mediation will rarely be successful until the numbers are disclosed with backup information.  The defense is usually adroit at seeing the weakness in the damage calculation.  If you want your mediation to be successful, come prepared for a discussion of damage items, their calculation and the causation for them.