Be reasonable. No matter which side of the fence you are on the tempation to “stick” it to the other side is strong when you are in the heat of a dispute. For counsel, helping a client see their way through this phase of the litigation is an art unto itself. This is made somewhat easier if there is some form of tangible result that might come from “reasonable” behavior. Michael Fitzgibbon of Thoughts from a Management Lawyer, posts on reasonable settlement offers in the context of human rights complaints. The case, Losenno, that Mr. Fitzgibbon refers to, is a strong reminder of the benefit brought on to the “reasonable” party in a dispute.