Settlement Negotiations Notes

You and the opposing appraiser spent a month going back and forth. Three position changes on each side, an umpire consultation on the depreciation method, finally a meeting in the middle on the dwelling number. By the time you close the file, that whole arc needs to fit into a few clean paragraphs that show how reasonable parties got to a reasonable result.

Skip this section or write it carelessly and the final award reads like it appeared from nowhere. Write it well and the award is the natural conclusion of a documented negotiation, which is exactly what a reviewing umpire or court wants to see.

This article covers what to capture, how to keep the tone professional, and what to leave out (hint: characterizations of the other side's motives).

What to Include

• Initial positions of each party
• Key points of disagreement
• Compromises made
• How agreement was reached
• If umpire involved, their role
• Final agreed amounts

Professional Tone

Keep the tone professional and objective. Focus on facts rather than characterizing the other party's behavior or motivations.