- Final disposition that day.
- You have two ways to win because you can either convince your opponent (like in mediation) or me (like in arbitration)
- I'm working with both sides to come to a joint decision. We're going to be discussing and arguing the case, in and out of caucus. You will be negotiating with me. So will your opponent.
- I'm trying hard to get a deal, but I'm able to let everyone know where I stand on issues as we proceed. That means you can convince me as we go, and it means you won't be surprised by the award if we can't agree.
- Use high/lows.
- Defense can get a "not guilty" because if they can't convince plaintiff to take their lowball offer, after extensive guided negotiation, I may ultimately agree that they're right. Alternatively, plaintiff could get a "home run" if the plaintiff can't convince their opponent to settle, I may ultimately agree that they're right.
I am strongly suggesting that you give this a shot – I think you'll find it can work.
Contact me for more details.