Providing David with an overview of the dispute is extremely helpful in preparing for the mediation session. This can include:

A description of the factual issues
A detailed description of damage claims,
The latest offers and demands exchanged by the parties
Any special requests regarding the mediation process.
Identify what the parties perceive to be any barriers which they have encountered to settling the dispute in the past
List three ideas which the parties would propose for overcoming the perceived obstacles to settlement
Documentary evidence deemed important to a party’s position should also be provided with the briefs or statements.

Before the mediation conference, please consider the following:
What are you intending by your opening offer or demand?
Why would the other parties be interested in this proposal?
What do you think the other parties are prepared to give or accept?
What is your best- and worst-case scenarios if the case is fully?