Based on the rules of negotiation for Alternative dispute resolution how should I argue this case in regard to the facts listed below towards winning a favorable decision with a mediator for Millie?

Millie Graves is 79 years old. For the past 15 years, she has lived in a second floor apartment in the Shady Nook apartment complex on N. Grand Avenue in Santa Ana, California. Millie pays $1,000 per month for her one-bedroom apartment. Approximately six months ago, the complex was purchased by Sam Simolean. About a month ago, Millie was mugged outside the front door of the apartment building. Her attacker had apparently followed her from the street, waiting until just before she entered the building, when she was in the shadow of the large maple trees growing in the front yard. There is a light over the front door, but it was not on that evening. The attack took place sometime between 9:00 and 9:30 p.m. Millie was not seriously injured, but she suffered bruises and scrapes when her assailant knocked her to the ground after he grabbed her purse. She lost all her identification, credit cards, and approximately $100 in cash. There is normally a resident manager living at the unit inside of the front door, but he was not on the premises at the time of the attack. Millie has never been a problem tenant. She doesn't complain and she pays her rent on time. For the past three months, however, she has withheld $500 per month from her rent in an effort to get Sam to make several repairs to her apartment. There is a leak in her shower, water damage to her kitchen ceiling from a leak in the apartment above hers, and two of her windows are broken. Her apartment has not been painted in two years, and it shows. There are also quite a number of roaches running around the building, particularly in the common areas. Millie has three cats, which was perfectly fine with her previous landlord, but Sam has instituted a "No Pets" policy for new tenants. Based on Millie's failure to pay her full rent for the past three months, Sam recently served her with an eviction notice, giving her 60 days to vacate the premises. The lease requires 30 days notice of termination for with or without reason at the landlord's discretion. Millie still has 15 months to go on a two-year lease. A mediation has been scheduled.

Millie is understandably upset about the eviction notice. She was just trying to get Sam's attention so he would fix the things that are wrong with her apartment. She wonders if the eviction notice isn't an attempt to keep her from suing for inadequate security in the building. She had noticed that the light was out for about a week before her attack, and the doorman told her that Sam was aware of it. She had also noticed that the doorman was frequently absent from his post, and several tenants told her that they had complained to Sam about it. Millie really doesn't want to move. She has always been very comfortable at Shady Nook, and it has become even more convenient since the new Metro station opened last year. She does have a married daughter who lives nearby with her family, but she could not stay with them indefinitely. Her daughter probably wouldn't mind, but Millie is very independent and a bit set in her ways, and really enjoys having her own place. She is also not sure she would be able to find as nice an apartment that she could afford. Her monthly income is $1, 200 from Social Security, $600 in survivor benefits that she receives on account of her late husband, George, and the income from a $60,000 certificate of deposit that she purchased with George's life insurance proceeds. She does not feel that she could afford more than $1,200 per month in rent. Millie also does not want to give up her cats. They have been with her for years. Babs is 12 years old, Danny Boy is 10, and Nunu is 8. They also help to keep the roaches out. You are willing to try mediation before a lawsuit is filed. If you don't get Sam to withdraw the eviction notice, Millie will be evicted.