Sure you have! You know, the party who challenges every single point to the very end [or to put it in another context, ‘we’ll all go down in flames if need be’] – that’s like the “Stalingrad Defense”. To get a better understanding of the concept, take a look at this article in The Connecticut Law Tribune about the divorce litigation that lasted longer than the marriage. What personal characteristic or characteristics would a good mediator need to have when faced with the “Stalingrad Defense”?
By the way, don't forget to turn your clocks ahead one hour Saturday evening at 2:00a.m. [or at some time that's more convenient for you]. If you happen to be mediating at that time, does that mean you get to bill for the extra hour? Have a good weekend!
To email me, click Perry S. Itkin.