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" ... The settlement form can also be run past opposing counsel in advance so that everybody is on the same page as to what the settlement agreement would look like going into the mediation. The parties themselves are then free to focus on the big-ticket items, and not get bogged down in their non-lawyer concerns about minutae. I suggest that it is much easier to think through these issues in the leisure of one's office before the mediation, than in the heat of mediation ⸺ and particularly at the end when everybody is exhausted and simply wants to go to home and take an aspirin (that is when somebody usually drops the ball). ... "