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In a pre-trial conference, having a separation agreement ready is considered best practice, even if it's not always feasible. The goal is to avoid trial, as it is not an ideal situation for anyone. It’s beneficial to draft a separation agreement when approaching a settlement, allowing for a clear presentation of terms. This can serve as a basis for discussions, where one party can send a draft agreement to the other, encouraging revisions that reflect both parties' positions. This approach fosters dialogue and may lead to a settlement without needing to go to trial.