Early Neutral Evaluation (’ENE’) is designed to allow the parties to streamline the litigation process in order to facilitate a more meaningful mediation early on in the case.

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ENE gives both parties a neutral's evaluation of their cases early on based upon known facts and applicable law. ENE is designed to help the parties identify key factual issues as to which limited discovery may be necessary. IDR will help the parties design a limited discovery plan with targeted requests for production and limited depositions.

Following the ENE and designed, limited and targeted discovery, the parties will be in a much better position to evaluate and negotiate a mediated solution with the help of the neutrals at IDR.