- I will know the legal issues either because I’ve already dealt with them or because you will have briefed me;
- I will know the factual issues- there are always competing narratives as well as your arguments about which witness is and not credible;
- I will listen hard very carefully to make sure that BOTH SIDES get far more attention than they would otherwise receive were the case to simply proceed to trial.
- When called for or needed I will use my four plus decades of trying cases- both plaintiff and defense (in nearly every type of jurisdiction from rich to poor) to bring additional reality to the process for both sides’ consideration.