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In preparation for a pre-trial conference, it's advised to have a separation agreement ready, even if not always practical. The focus is to avoid going to trial, making separation agreements essential. It's beneficial to draft one when nearing a settlement, allowing for an organized presentation of terms. If a settlement offer is made in letter or bullet-point form, it's effective to send a draft separation agreement that outlines your client's position, inviting revisions. This approach facilitates dialogue and helps progress towards reaching an agreement.