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okay so with respect to a separation agreement best practice is to go to your pre-trial conference with a separation agreement if you can it's not always realistic but Carlos can speak a little bit about the actual mechanics of putting together a separation agreement and what you need to make sure you are keeping in mind on your checklist so separation agreements are the goal right you don't want to go to trial nobody wants to do that exercise go through that exercise so at the time when it becomes appropriate you might want to draft the separation agreement just to have one handy in case that you are getting close to a settlement and in case that you can just hammer out the details and present one and sometimes we'll even in lieu of a settlement offer that's in a letter farm or bullet points we'll just draft a separation agreement and send it over and say this is our clients position feel free to make revisions that reflect yours and we'll go from there that just gets the dialogue go...
