LEVERAGING NEUTRAL EXPERTS IN ADR
FOR REAL ESTATE DISPUTE RESOLUTION

Arizona Bar Association | April 17, 2025

PRESENTED BY:
Sally S. Duncan, Retired Superior Court Judge
Bruce D. Greenberg, FRICS, MAI, SRA, SRA
MODERATED BY:
Benjamin Greenberg

ARTICLES:

Each article is grouped by the slide it corresponds to, making it easy to follow along and dive deeper into specific topics covered in the presentation.
SLIDE 2 - Why Neutral Expertise and ADR Selection Matter

Neutral Analysis: An Overlooked Tool for Understanding and Settling Disputes

Author: JAMS

Publication Date: 2023

Summary: Introduces neutral analysis as a tool for evaluating case strengths and weaknesses to facilitate resolution.

Link: Neutral Analysis – JAMS

Early Neutral Evaluation: Getting An Expert’s Assessment

Author: American Arbitration Association

Publication Date: Approx. 2016

Summary: Outlines ENE process and benefits in early litigation.

Link: ENE – AAA

SLIDE 3 - Early Neutral Evaluation (ENE) as a Pre-Litigation Strategy

Early Neutral Evaluation: Getting An Expert’s Assessment

Author: American Arbitration Association

Publication Date: Approx. 2016

Summary: Outlines ENE process and benefits in early litigation.

Link:ENE – AAA

An International Review of Early Neutral Evaluation Programs and Their Development

  • Author: Kaitlin A. Roh
  • Publication Date: 2023
  • Summary: Comparative study of ENE implementation across jurisdictions.
  • Link: University of Calgary

 

Mandating Early Neutral Evaluations: Efficient or Excessive?

SLIDE 4 - Practical Roadmap for Implementation

Judicial-ish Efficiency: An Analysis of ADR and Settlement in Federal District Courts

  • Author: Michael P. Fix
  • Publication Date: 2022
  • Summary: Examines ADR efficiency in federal court systems.
  • Link: Washington & Lee Law Review

The Role of Mediation and Arbitration in Resolving Real Estate Disputes

  • Author: Peterson Law LLP
  • Publication Date: 2024
  • Summary: Emphasizes the flexibility of ADR in real estate matters.
  • Link: Peterson Law Article
SLIDE 5 - Integrating Experts into Mediation & Arbitration

Dispute Resolution Process: Combining Mediation and Arbitration with Med-Arb

  • Author: PON Staff
  • Publication Date: 2024
  • Summary: Explains the hybrid Med-Arb structure and when it works.
  • Link: PON – Harvard

Neutral-Driven Dispute Resolution — The Missing Piece of ADR

  • Author: Robert A. Cole
  • Publication Date: 2022
  • Summary: Argues for proactive, expert-led resolution in ADR.
  • Link: Florida Bar Journal
SLIDE 6 - Understanding Expert Bias in Private Disputes

What is a Neutral Third Party?

  • Author: PON Staff
  • Publication Date: 2025
  • Summary: Defines the function and importance of neutrality in ADR.
  • Link: PON – Harvard
SLIDE 7 - Med-Arb and the Dual Role of Neutrals

Combinations of Mediation and Arbitration with the Same Neutral: A Framework for Judicial Review

  • Author: Ellen E. Deason
  • Publication Date: 2013
  • Summary: Legal analysis of dual-role neutrals in ADR and due process.
  • Link: Scholarly Article

Getting Your Most Beneficial Dispute Resolution by Combining ADR Processes

  • Author: PON Staff
  • Publication Date: Approx. 2018
  • Summary: Explores how combining ADR formats improves outcomes.
  • Link: PON Article
SLIDE 8 - Ethical Considerations for Attorneys and Neutrals

Judicial-ish Efficiency: An Analysis of ADR and Settlement in Federal District Courts

  • Author: Michael P. Fix
  • Publication Date: 2022
  • Summary: Examines ADR efficiency in federal court systems.
  • Link: Washington & Lee Law Review

The Role of Mediation and Arbitration in Resolving Real Estate Disputes

  • Author: Peterson Law LLP
  • Publication Date: 2024
  • Summary: Emphasizes the flexibility of ADR in real estate matters.
  • Link: Peterson Law Article