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expert opinions, retaining and producing old documents and electronic information, thelogistics of dealing with over 100 plaintiffs bringing wrongful death and survivorshipclaims, defending serious (and higher-value) bodily injury claims, ensuring that allstakeholders were accounted for in settlement discussions, and responding to theunyielding demands of the investigating governmental agencies.Ultimately, the lawsuits and most ancillary claims settled, but spin-off litigation continuedfor several more years. This catastrophe implicated nearly every conceivable issue thatmight be involved in “catastrophic litigation.” At the end of the discussion, it is thepanel’s hope that attendees and readers will benefit from the following “lessonslearned.”IV.Before the Storm: Is it Possible to Prepare for a Catastrophe?Even though catastrophes may be completely unforeseeable, companies who work onhigh-risk projects can be prudently proactive when things are quiet.A. Choosing Work CarefullyAll transactions of any complexity present a risk of serious future exposure that will befar in excess of what the work was worth. Since companies that take no risk do nowork, it is unrealistic to expect lawyers to advise clients to turn down attractiveopportunities, especially in a competitive economy.Instead, it would be ourrecommendation that your company would at least conduct a careful, up-front business

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