I am defending an employment discrimination case. Because of the underlying facts, I think an Offer of Judgment would be a good tactic. My question is whether it would be better to make an en globo offer or break it down into elements - economic damages, non-economic damages, etc. And how to address attorney fees? Include in the en globo offer, break out as a separate element, or provide for submission of the issue to the court for approval? I'd welcome any thoughts or personal experience either way. And apologies for cross-posting - don't know how much overlap there is between the two list-servs. Henry M Bernstein Assistant Parish Attorney Caddo Parish, Louisiana (318) 226-6947 hbernstein@caddo.org ________________________________ PRIVILEGED & CONFIDENTIAL COMMUNICATION This e-mail message (including any attachments) is proprietary or privileged and intended only for the named recipient(s). It may contain material that is privileged, confidential and exempt from disclosure. No one other than the named recipient(s) may read, copy, rely on, redirect, save or alter all or any part of the message, or any attachments, in any way. If you have received this message in error, please notify us immediately by return message so that we may arrange return of the document(s). ________________________________