You know, I find myself with a different suggestion. Gerda has no attorney to punt this off to and wants a resolution of this stressful and draining case with no trial date in sight, and in fact recently tried to get him to go to mediation for that reason.
Taking a common sense approach, I would be more likely to say something like:
Dear Professor (can he really have any other name?):
I would be happy to sit down with you and work out a global settlement of all issues pending between us so that we can both move forward productively. I'm sure you can appreciate that just as you have this issue that you believe requires my cooperation, I too have matters on which I require your cooperation. Let me know when you would like to meet.
Would I help him out without a global resolution (nope). Does it really matter why he is coming forward? Maybe this is a safer feeling approach because he is ready to get it done finally. Not likely, but it is a possibility. Will he do it? Probably not. Would it make Gerda look more reasonable if he files an emergency motion claiming that she is preventing him from meeting basic needs? Obviously Gerda knows her situation and her facts and what she hopes to achieve, and has to decide what is in her best interest.
