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Using the Tracker in a Negotiation

This guide walks you through using the Settlement Tracker from start to finish during a live negotiation. Whether you are at a formal mediation or tracking offers exchanged by correspondence, the workflow is the same.

Before the Negotiation

Set up the session before the mediation or conference begins, so you are ready to record offers as soon as negotiations start.

Create a session. Open the case from your dashboard, click the Settlement Tracker tab, then click New Session. Give it a descriptive name such as "Smith v Jones -- Mediation 20 March 2026".

Enter party names. Type the plaintiff and defendant names into the fields at the top. This is important because these names appear on the downloaded report -- so make sure you enter them correctly from the start.

Set the mode. Use the Plaintiff / Defendant toggle at the top of the tracker. Choose the mode based on which side you are advising:

  • Select Plaintiff if you are acting for the claimant -- the tracker will calculate net take-home amounts (what your client actually receives after expenses are deducted).
  • Select Defendant if you are acting for the respondent or insurer -- the tracker will calculate total settlement cost (the accepted offer plus the defendant's own costs).

Add costs and expenses first. Before recording any offers, enter all known costs and outlays. Use the Quick add buttons for common items -- Legal Fees (Own), Barrister Fees, Medicare (Notice of Charge), and others. Enter the dollar amount for each. Click Custom to add items not in the quick-add list.

💡 Tip

Entering your expenses before the first offer means the take-home analysis updates automatically as each offer is recorded. This saves time during the mediation when decisions need to be made quickly -- you can see the net position at every offer without doing mental arithmetic.

During the Negotiation

As offers are exchanged, record each one in the tracker. The chart fills out showing offers going back and forth at each exchange, and the position cards update in real time.

Record the opening offer. Click Add Offer. Select the party (Plaintiff or Defendant), enter the date and time (which default to now), enter the amount, and optionally add notes (e.g., "Opening position, inclusive of costs"). Click OK to save.

Record the counter-offer. When the other side responds, click Add Offer again, select the opposing party, and enter their amount. The position cards, gap, midline, and chart all update instantly.

Continue recording exchanges. As the negotiation progresses, keep adding each offer. The negotiation chart builds a visual history of the offers, and the movement info bar shows how far each party has moved from their opening position and the total combined movement.

Check take-home amounts. Before responding to an offer, scroll to the Take-Home Analysis section to see the net-to-client at the plaintiff's position, the defendant's position, and the midline. Use the Quick Calculator to test any amount -- for example, "say if it gets to $200,000, what's it going to be?" Type in the figure and the net result appears instantly.

Watch the gap and midline. The Gap card is very helpful to see if you are getting towards the business end of things. The Midline shows the settlement value you are tracking to if both parties keep up the current pace in terms of the intervals between their offers. It is common to see consistency in intervals at the start of a negotiation, until people start to see the end approaching and the limit of their instructions with it, and start to tap the reins.

ℹ️ Note

All changes are auto-saved. If your browser closes or you lose connectivity, your data is preserved. The save status indicator at the top of the page shows "Saving..." and then "Saved" after each change.

After Agreement

Mark the agreed offer. When the parties reach agreement, find the accepted offer in the Offers table and click the green tick icon. The tracker displays a green banner showing the agreed settlement amount and the net to client (or total cost in Defendant mode).

Export the record. Click Download DOCX at the top of the page to generate a formatted Word document of the entire session -- parties, offer history, negotiation summary, expenses, and agreed settlement. This is very helpful to then populate your advice to the client at the end of the negotiations. Save it to your file as a permanent record.

Tips for Live Use

  • The more visual you can make things and the more involved you make the client, the easier the conversations will be. Share your screen or turn your laptop to show the chart during a mediation -- clients find it much easier to understand the trajectory of a negotiation visually than through raw numbers alone
  • Rename the session at any time by clicking the session name at the top and typing a new one
  • Update expense amounts as they are confirmed during the mediation (e.g., a final Medicare notice figure)
  • Use notes on offers to record conditions, such as "Subject to instructions" or "Without prejudice, inclusive of costs"
  • If negotiations break down, the session is preserved. You can return to it later and continue recording offers from a subsequent round
  • You can track negotiations as individual sessions or across the entire life of the case -- use multiple sessions to keep separate rounds distinct, or a single session to see the full picture

Next Steps

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