Well, I usually will talk to the parties and ask ‘em at that point in time, once there’s been a stop in the negotiations if you will and nobody’s willing to make any moves.  Separately, I’ll talk to them.  “Can you give me your secret number?  If we can settle this case today, would you tell me in a highly confidential basis where you need to be?”

And then I’ll go to the other side too, and I say, “Can you tell me in a highly confidential basis, I’m not gonna tell the other side, but where you really need to be today?”  And a lot of times, when I get the two secrete numbers, they’re within 10 or 15 percent of each other, and I call the number beforehand, playing like Liar’s Poker, you know?  What, really, cards do you have?  What do you really want to do?

And then if I find out they’re within that 10 or 15 percent range, it’s pretty easy to close the gap at that point.  Then, you know, reality is probably right in the middle there of those two secret numbers.  So, I use that quite a bit.

And sometimes, too, I’ll get the lawyers separately in a room.  Usually, we’re meeting in separate rooms all day, and I’ll tell the parties I’d really like to talk to the lawyers separately just for a few minutes, and I’ll try and have a candid discussion with them.  Say, “Gentleman, we’re about ready to break, and we’re almost at an impasse.  What do you really need to try and accomplish today?  And is there anything else you think I should do as a mediator?”

And I don’t want that meeting to take more than five minutes, ‘cause the parties might think we’re talking behind their back, you know.  But sometimes a candid discussion with the lawyers is very helpful too.