10 QUESTIONS ON ADR
10. What else do I need to know?
Be prepared.
Don’t fool yourself into thinking that you can wing it because it’s only ADR. While the focus of your preparations may be different, your client deserves your best effort. Think through your arguments. Document the critical facts. Organize your materials and presentations. Pack a calculator. Confer with, educate and prepare your client, as well as any other participants you may involve. Discuss realistic settlement ranges and alternatives with your client. Articulate your theme and theory of the case. And get a good night’s sleep. Then you will be ready to seize the day.