Hi - my name is XXXXX XXXXX I'm a Business litigation attorney. Thanks for your question.
USUALLY, settlement talks don't begin until after discovery is exchanged between the parties. This allows each party to evaluate the positive and negative things about their cases and also allows them to evaluate the strength/weakness of the other party's claim against them.
In a breach of contract case involving a non-compete, much of the argument is going to revolve around the terms of the agreement AND what things are covered by the agreement.
Thus, usually after both parties disclose their evidence and positions through discovery, the parties can sit down and try to mediate the case. Mediation is a helpful tool and courts USUALLY order it before a trial date can be set. Thus, this is when and where most cases are resolved.
There are no standard strategies or pitfalls except for trying to sell your position as best you can AND try to point out the weaknesses of your opponent's case. The only real strategy is to be OBJECTIVE when viewing your case and be REASONABLE with what you're seeking because you don't want to over-value your claim.
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