Despite how passionately a recovery professional feels about the liability existing against an adverse party, despite the plethora of support documentation, including expert reports and even obtaining the cooperation of the policyholder and the fact that you, as the subrogation representative, have attempted to utilize all of your very best negotiation skills and tactics, the adverse party refuses to settle, or even negotiate. It’s time to face facts: Your perfect case has now reached an impasse. Now what? Appropriate goals for every recovery representative should involve obtaining the best recovery for the company, carrier, or client (as well as for the policyholder) in the shortest time possible.