First thing I would say is they owe you what is fair... nothing more and nothing less. Don't settle for less than what is fair. I don't believe unless you are claiming against your own insurance that you should have to deal with depreciation. You should only accept replacement value, again, nothing more and nothing less.

If you even potentially lost revenue from being able to rent out the equipment to someone else then that should be considered as well. You should in fact be made whole.

Just my two cents. Be careful and calculated in your wording. Not manipulative yet very frank and absolute. Put them in your shoes and ask them if they would accept anything other than what is fair. Make them ultimately responsible for justifying why they came to a certain settlement point. Accepting their first offer, unless fair, is probably not the best you can do.

If there is any question, use the book "Getting to Yes" as a guide in helping you to a settlement.