If you are in settlement negotiations with me, and it is your goal to make sure the case does not settle,* here are several things you can say:**

1. My client is very emotional about having to comply with the regulations because he supports a disabled baseball team.
2. My client is very emotional about having to comply with the regulations because he has Parkinson’s.
3. I know you feel like you want to create a more enjoyable experience for the disabled, but that’s not what the statute requires.
4. My client refuses to create an annuity for plaintiffs’ lawyers.
5. With that damages demand, let’s just turn the state of California over to the disabled!

I realize I’m providing advice to my opposing counsel, but sometimes you just gotta reach out.

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*  There are many reasons why this might be a defense counsel’s goal:     (1) Billable hours.  (2) Billable hours.  (3) Billable hours.  … (n) Billable hours.

** All of these are real.  Really.