Respond to the brief scenario below.  You don’t have to know all the legal niceties, so don’t let that bother you.  I’m looking more for your analysis about how you will prepare yourself.

Scenario:

You will be negotiating with one of the most well known products liability lawyers in the country. You represent the manufacturer of a product which allegedly injured this attorney's client.  She has tried numerous juries and obtained many verdicts in the millions.  She is known as a gunslinger, and is not at all afraid to try a case.  Your client is a large national company and clearly has solid defenses to the various claims the potential plaintiff might make.  This doesn't mean you will absolutely prevail, but you feel the odds significantly favor your client because of the legal precedent in your state.  You feel the potential plaintiff, who has serious injuries, cannot afford to wait long for settlement.  Nonetheless, your client has concerns about reputation and is risk averse and does have a desire to settle, rather than litigate.  For purposes of your answers, we’ll simply refer to the product in question as a widget. 

 (I’m thinking three or four paragraphs – more is okay but not required) the kinds of things you will want to ask your client before entering negotiations with this attorney.  Also, explain how you might approach the lawyer on the other side, given her reputation, to obtain whatever information might be helpful in preparing to negotiate a resolution.