Ten pages is plenty
What I actually read before your session, and what I skip.
Position statements have gotten longer every year I have practiced. I understand why. The statement is the one document a mediator reads without opposing counsel arguing over it, so the temptation is to put everything in. The result is usually forty pages that restate the summary judgment briefing, and the part I needed sits on page thirty-one.
Here is what moves a case in the room. Tell me the two or three facts that decide liability, and tell me which of those facts your opponent disputes with something more than argument. Tell me what discovery has actually produced, not what you expect it to produce. Give me the damages model with the arithmetic shown, including the number your expert will testify to and the number your client would take today. Tell me who from your client is coming and what that person can approve without a phone call.
Then tell me the part that never appears in the pleadings. A distributor who wants an apology in writing. A founder who cares more about the non-disparagement clause than the money. A carrier with a reserve set before anyone deposed the plaintiff. Those are the constraints that decide whether we close, and they are invisible unless someone says them out loud.
Mark the confidential portion clearly and I will keep it confidential. Attach the exhibits that matter and skip the ones that do not. Ten pages is plenty. If your case genuinely needs more, send more, but send it a week out so I have time to read it properly.