Put yourself in your opponent's shoes. When you propose a specific settlement, make it clear that you're attempting to compromise. If a settlement is reached, promptly write it down and have all parties sign it. You or your lawyer should volunteer to prepare the first draft. That way, you can include protective language that, once included, your opponent may see as too minor to quibble about.
Money is a powerful incentive to settlement.
The other side may settle at a surprisingly low figure if they can walk away from the bargaining table with payment in hand. Of course, if you pay with cash, be sure to get a receipt. All rights reserved.