In employment cases, money is rarely the whole deal
The terms nobody pleads are often the ones that close the gap.
Employment matters sit closer to the person than most commercial disputes. On one side is someone who lost a job and usually a professional identity along with it. On the other is a company weighing this settlement against every other claim on its desk and against the people still working there. Both sides arrive with a number, and the number is almost never the only thing in the way.
The terms that close these cases are frequently the ones that cost the employer very little. How the separation is characterized. A neutral reference and a named person who handles verification calls. What the personnel file says. Whether the non-disparagement obligation runs both directions. A resignation date that lets someone finish a certification or reach a vesting cliff. Bring a draft of those terms to the session rather than waiting to see whether the money resolves first, because it often will not without them.
Employers have real constraints that are worth stating plainly. Precedent for the three similar claims that have not been filed yet. A carrier with its own view. Board or corporate approval on anything past a threshold. Allocation between wages and non-wage damages, which changes what the plaintiff actually nets and what the employer withholds. Say these out loud early. A plaintiff who hears why an employer cannot agree to reinstatement will often trade it for something the employer can give.
Two practical notes. The person with authority over money is not always the person with authority over reference language, so make sure both are reachable. And build in time to draft. Allocation, tax language, and reference terms take longer to write than the parties expect, and I would rather we spend forty minutes getting the agreement right than sign something at 5:25 that counsel has to fix by email the following week.