1. Get to know opposing counsel. Consider asking him/her to lunch at the outset of the case before discovery, motions, etc., just to get acquainted.

2.  Return phone calls, e-mails in a timely fashion.

3.  Remember who you are. One “difficult lawyer” is one too many. It’s the parties’ case — not yours.

4.  Try to review any written pleading with “new eyes” after the draft has had a day or two to “cure.” Avoid the use of disparaging terms such as “This claim is ridiculous” or “Opposing counsel’s arguments are specious.”

5.  Establish trusted mentor-mentee relationships. Never be afraid to seek advice from a trusted colleague, whether in your own firm (if you’re in a firm) or from someone you trust. Sometimes, the best guidance can come from a worthy opponent in a previous case.

6.  Your comportment in depositions is the same as in court. If opposing counsel is not observing this practice, you should professionally and courteously remind her/him of this practice.

7.  Develop a reputation for extending professional courtesies (e.g., extensions of time). It is entirely appropriate to memorialize your understandings in writing. (E-mail is acceptable.) This does not mean that you should become a “patsy” or that you should do anything that compromises your client’s genuine interests.

8. Always arrive at court, depositions, meetings, etc. on time.

9.  Never hesitate to ask for a “time out” to cool emotions.

10. Don’t assume the worst.