Counsel must respond promptly to inquiries and communications from opposing counsel. These revised Guidelines will give direction to both lawyers and judges concerning how lawyers should conduct themselves in all phases of trial practice.Do not agree to record a statement and do not say yes to a settlement offer without first discussing it with a personal injury attorney. Engaged in settlement negotiations on behalf of the claimants with opposing counsel. Neiman acknowledged that he relayed a series of offers and counteroffers. Sometimes emotions may be driving the dispute which can make talking to the person or party with whom you are in a dispute difficult. You and your opposing counsel are headed to a settlement conference with a judge. Step 2 — Fill out Forms. See In re Letters Rogatory out of First Civil Court of City of Mexico, 261 Fed.