# 03 — Content and voice Authority: `AGENTS.md` §4 (claim register) and §5 (audience model). Source material: `PL_ADR_Personal_Branding_Strategy_Brief.docx` (2026-05-26) and `ADR_Site_Content_Brief_for_Claude_Design.md` (2026-05-26). --- ## The one rule **Every factual claim traces to `AGENTS.md` §4 Verified.** Read the Forbidden table before writing any number, statistic, or superlative. If you need a fact you do not have, write `TODO(pouya): ` and log it in §9. Do not infer, do not soften, do not carry anything over from the old site. ### When a fact is `[unestablished]`, write around the capacity question **Ratified by Pouya 2026-08-28 as a reusable pattern, with the instruction that it will recur.** §4 records licence status as `[unestablished]` and says: *do not assert it, do not deny it.* Copy that addresses the question at all must therefore pick neither side — and the trap is that **both obvious phrasings pick one.** The worked example, which took three attempts and two audits: | Attempt | Copy | Why it failed | |---|---|---| | 1 | "I **do not** give legal advice" | *"Do not"* is an **election** — it implies entitlement withheld by choice. Flagged by audit 1 | | 2 | "I **cannot** give legal advice" | *"Cannot"* is a **denial** of capacity. Flagged by audit 2 | | 3 ✅ | "I act as a neutral. I do not act for a party in a matter I take, and each party should have their own legal advice." | Makes **no capacity claim at all** | **Both audits were right, and that is why the third version works.** Attempts 1 and 2 are opposite answers to the same question, so flagging both is not inconsistency — it is the correct finding twice. Pouya: *"'do not' elects, 'cannot' denies, and §4 says do neither. The shipped sentence makes no capacity claim at all — it describes the role and points the reader somewhere useful."* **The pattern, stated for reuse:** > Do not look for a *softer* way to answer the capacity question. Any word that > answers it — *cannot, do not, am not, is not permitted, is not qualified* — > takes a side of a fact this register does not hold. Instead write the sentence > so the question **does not arise**: state the **role**, state the > **consequence** for the reader, and stop. Three tests before shipping such a sentence. It fails if any is yes: 1. Could a reader infer from it that he **is** entitled to do the thing? 2. Could a reader infer from it that he is **not**? 3. Does it contain a verb of capacity or permission attached to him at all? **Where this will come up next:** `/practice/` (step 5) and `/for-parties/`, both of which have to tell an unrepresented party what the neutral will and will not do for them — the exact place the "cannot" phrasing feels most natural and is most wrong. --- ## Voice **Restrained, precise, and unhedged.** The reader is usually a lawyer. They detect padding instantly and discount everything after it. **Do:** - Short declaratives. "I read the contract and the code." Not "clients benefit from a uniquely multidisciplinary perspective." - First person singular. This is a practitioner brand — "I", not "we", not "the practice". The old site's "we" implied a firm that does not exist. - Concrete nouns. *Lien claim. Change order. System Impact Assessment. Model card. Minutes of settlement.* Specificity is the credential. - Name the limits — but name the *right* ones. This bullet carried the model sentence *"Sole-arbitrator appointments follow the Q.Arb designation; co-arbitration work is available now"* until 2026-08-26. **Both halves were wrong and they were wrong in opposite directions**, which is why it survived two audits: the first half understated (sole-arbitrator appointments are offered **now** and are not gated by Q.Arb — §4 Offerings), and the second was unsourced when written. §4 now carries rows for all three forms. The shape of the bullet still stands, so here is a sentence that fits it and clears the register: *"I accept sole, party-appointed and co-arbitration appointments **in commercial matters**. The Q.Arb **pathway** commenced in August 2026; C.Med-Arb is the endpoint."* **"in commercial matters" is not optional** — every §4 Offerings arbitration row is scoped commercial, family arbitration has its own NOT OFFERED row, and §4's NOT-NEGOTIABLE boundary records the unscoped class form as the struck universal (Q39). This model sentence was unscoped until 2026-08-28 while the shipped page it feeds was scoped; found by `claims-auditor` on re-audit, one file over from the same defect fixed in `docs/04` earlier the same day. **"Pathway", never "designation"** — a *designation* that "commenced in August 2026" reads as in force since then, i.e. **held**, which §4 Forbidden bars outright. This model sentence said "designation" until 2026-08-28 and it is copy an implementer is told to lift; found by `claims-auditor`. The limit being named is the **stage of the arc**, stated plainly — Pouya's instruction is that being open about it is the differentiator, so do not hedge it into vagueness and do not drop it. (**No tribunal-secretary work** — D14 removed the rate and bars offering it; see `docs/07-fees.md`.) Precision about what you cannot yet do makes the rest believable. - Plain words over Latin. "Without prejudice" survives because it is a term of art; *inter alia* does not. **Do not:** - **Any claim or implication of legal licensure.** D13: the site asserts the JD and nothing more. Never "lawyer", "called to the bar", "licensed", "my law practice", "my litigation practice", "my clients", "acts for", "represents". Implication counts as much as assertion. **The approved phrasing is "active litigation exposure" or "involvement in litigation and ADR matters" — never "practice" in that context.** Pouya's wording, 2026-08-26. So: *Director of Firm Operations at a Toronto litigation and ADR boutique, with **active litigation exposure** across construction, personal injury, POA, and SABS matters.* Accurate, specific, and it claims nothing it should not. *(This example read "with active exposure to" until 2026-08-28 — a **third** variant of the phrasing, three lines below the sentence naming the only two approved forms, in the one place where the wording IS the compliance. Found by `claims-auditor` on re-audit.)* This framing is **interim** — see `AGENTS.md` §12 R1. Raise it with Pouya rather than letting it settle in by default. - Superlatives. No "leading", "premier", "top-rated", "best". They are unverifiable, they read as insecure, and marketing rules for regulated professions treat them as suspect. - Outcome language that could be read as a guarantee. - "Passionate", "dedicated", "committed", "proven track record", "results-driven", "leverage", "synergy", "solutions". - Hedges that erase the claim. The strategy brief warns specifically against softening the technical claim to "technologically literate" — **the claim is engineering practice, so the copy says engineering practice.** - Em-dash-heavy rhythm and tricolon padding. One idea per sentence. - Second-person sales copy on counsel-facing pages. `/for-parties/` is the one page written to "you". --- ## The core positioning statement Reused, adapted, across the hero, the About page, and the PDF bio: > The dispute resolution practice of Pouya Lajevardi — a credentialed neutral > with active litigation exposure and a practising machine-learning and > infrastructure engineer. Built for commercial, construction, energy, > technology, and cross-cultural disputes that turn on the contract, the code, > the engineering documents, and the regulatory overlay around them. Every version of this must survive the §4 check. It does: each element is verified. **AMENDED 2026-08-27 — `AGENTS.md` Q41(b). The statement read *"disputes that turn on facts most neutrals take on faith: the contract…"* and the comparative is struck.** It was not restored, and Pouya gave two reasons, the second of which is the one to remember: > "That is an unverifiable empirical claim about other practitioners, and > comparative claims must be factual and verifiable. **It is also weaker copy: > assert his capability, not the field's incapability.** Rewrite to claim only > about himself — 'built for disputes that turn on the contract, the code, and > the engineering documents'. Same force, nothing to defend." So the compliance objection and the editorial objection point the same way. The checklist item below — *"any comparative claim is factual and verifiable"* — had been overridden in practice by the fact that this paragraph was **approved copy**, which is how an unverifiable claim ends up inside the document that forbids it. The approved copy is what changed. **This is now the ONLY sanctioned form of the statement.** Any earlier draft carrying the comparative is superseded, wherever it is quoted. ## Approved headline options From the content brief; all three sit honestly with the practice. 1. *A mediator who reads the contract, the code, and the room.* — **recommended.** The cleanest one-sentence statement of the moat, and rare because it is rare. 2. *Engineered for the cases that don't fit a courtroom.* 3. ~~*Disputes resolved by someone who has been on every side of one.*~~ **Does not clear §4 as written** (flagged 2026-08-26). "Every side" asserts having acted as party, as counsel, and as neutral; §4 verifies the neutral role and *active litigation exposure*, not the other two. Left in place so the option is not silently re-invented — but it cannot be chosen without a §4 row to choose it from. ## The credential row Three slots, never counts: | Slot | Value | Label | |---|---|---| | 1 | **Q.Med** | ADRIC / ADRIO designation | | 2 | **JD + ML** | Legal training and engineering practice | | 3 | **EN · FA** | Bilingual practice | **Slot 2's label changed on 2026-08-27 (Pouya, `AGENTS.md` Q37).** It read *"Law and engineering"*. His reasoning: *"The parallel was doing the implying — a degree and a practice under one noun. The asymmetry is the honest part."* A JD is a degree; engineering is a practice, and a verified one. Setting them in parallel invited the reader to supply the symmetry, and for "Law" the missing half is a licence — which D13 bars by implication as hard as by assertion. The replacement is longer and deliberately lopsided. Do not tidy it back into a parallel. **AND THE RULE IS NOT SCOPED TO THIS LABEL — `AGENTS.md` Q41(a), Pouya 2026-08-27.** Q37 was asked about a credential label; the reasoning applies to every surface, prose included: > "Yes, Q37's reasoning reaches prose. The implication test applies everywhere, > not just to labels. **Prose has more room, so it is easier to satisfy: state > the asymmetry explicitly rather than relying on a parallel construction to > carry it.**" Read the second half carefully, because it sets a **higher** bar for prose, not a looser one. Deleting the parallel is only half the job — a reader can still supply the missing symmetry from silence. Prose has room to say which half is which, so it must. Naming the legal half as **training** is what makes the licence implication impossible rather than merely absent. **THE SENTENCE IS A CONSTANT, NOT COPY TO BE RETYPED** — `ASYMMETRY_LINE` in `src/data/site.ts`: > "The two halves are not the same kind of thing, and the asymmetry is the honest > part. A law degree on one side. A working engineering practice on the other. > One is training I hold. The other is work I still do." It lives beside `ROLE` for the reason that file gives: *"these are the two where the wording IS the compliance."* This paragraph previously quoted it inline and cited it as living at "`/`, §The approach" — and by then it had been typed into `/about/` too, so there were **three copies and two of them had already diverged**: a comma here and on `/`, full stops on `/about/`, all inside the session that wrote them. Consume the constant on any page that needs the sentence. Do not retype it, do not paraphrase it, and do not quote a variant of it in a spec. Fourth slot where the layout has one: **Q.Arb — commenced August 2026.** Use that wording, not "in progress": §4 pins it, and the weaker form drifts toward "nearly complete", which §4 Forbidden bars outright. **On the home page the fourth slot IS used, and it is not optional there.** `docs/01` §`/` says "Three slots"; §4's paired-disclosure condition is the higher authority and requires that wherever the site offers arbitration it "states plainly" the stage of the arc. `/` says *arbitrator* in its opening sentence, so the stage belongs on the same page rather than only in the footer. Rendered as value `Q.Arb` over label `Commenced August 2026` — the same wording, with the em-dash carried by the layout instead of by the string. The substitution principle (`AGENTS.md` §4): wherever the design wants a "how many", substitute a longer-arc credential. These are all true at launch and stay true; none grows by closing files. --- ## Per-page copy notes ### Home Hero headline from the approved list. Positioning paragraph above. CTAs: *Request a consultation →* and *How I work*. The approach section makes the "two directions at once" argument — law and engineering converging on the same dispute — and keeps the infinity metaphor: *disputes are loops; the work is redrawing the loop into a line.* First person: "my mark", not "our mark". > ⚠️ **"law and engineering" IS THE STRUCK CONSTRUCTION. Do not lift this > sentence into copy.** The *argument* it names is Pouya's and stands; the noun > pair carrying it is what Q37 struck and Q41(a) extended to prose. It reached > the page once already, as *"Law and engineering are not blended here"* — the > struck parallel relocated from the credential label into body copy, one day > after it was struck, and strengthened by attributing both halves to him > personally. A spec phrase describing an argument is not approved copy. ### About 400–600 words of narrative, then structured credentials. Tell the three tracks as one arc, not three lists: a JD and active litigation exposure; a parallel career in machine learning and infrastructure engineering; a company run alongside the practice — §4's wording; "alongside both" was a concurrency claim the register does not make. The arc is the point — the credentialing pathway from Q.Med through Q.Arb to C.Med-Arb is stated openly, **with Q.Arb described as commenced August 2026** and never as "in progress", which is looser than §4 and is barred by `docs/06`'s cutover checklist. The brief treats that arc as part of the story rather than something to obscure. The designation names expand as **Qualified Mediator**, **Qualified Arbitrator** and **Chartered Med-Arbitrator** — ADRIO's own forms, sourced in `docs/reference/adrio-designations.md`. Never "Chartered Mediator-Arbitrator". Omit any section that would be empty. No "Speaking" heading until there is a talk to list. ### Mediation / Arbitration / Med-Arb Procedural, specific, unembellished. Name the rules. Describe the formats. State what a party should expect to do and when. On `/arbitration/`, state the Q.Arb position in plain terms — what is available now versus what follows designation. `/med-arb/` addresses the procedural-fairness objection directly: the same neutral who heard a party's confidential caucus later decides the matter. Do not elide it. Explain the consent mechanics and when the process is inappropriate. Meeting the strongest objection is what makes the page worth reading. ### Practice areas Each page: dispute types, why this practice fits, what the process looks like, and the market context that makes the area live. Context comes from the strategy brief §III–IV — Ontario's megaproject pipeline, Bill 40 and grid connection, the 2026 privacy statute, LAT volumes. **Frame as positioning, not as history.** "Built to facilitate procurement and subcontract disputes on Ontario's megaproject pipeline" — not "extensive experience resolving". The first is true and forward-looking. The second is neither. ### Process Five steps with real timing. Say what happens if the matter does not settle — counsel want to know the downside shape before they commit a client's day. **AMENDED 2026-08-27 — `AGENTS.md` Q43, and it overrides this section's previous reading.** "Real timing" was being read as *barring* the word "typical", which is why the step-2 build shipped the five timings as bare numbers and escalated the question instead of framing them. Pouya ruled the other way: > "The five process timings are **service commitments, same class as Q27's > response time** — not facts about Pouya, so they need framing, not a Verified > row. Present them as the TYPICAL shape of an engagement, explicitly not a > guarantee: mediation timing depends on party and counsel availability, which > he does not control. **Published as typical, they are honest and useful; > published as commitments, the first matter that slips makes the page false.**" So: the **numbers do not change** — softening them was never the fix and inventing them was never on. What "real timing" bars is a *vague* timing ("promptly", "in a matter of weeks"), not an honest statement of what the numbers are. The framing is `PROCESS_FRAMING` in `src/data/site.ts` and it is **not optional**: every page that renders the steps renders it, adjacent to the numbers rather than in a section lede above them. A reader who scans the strip and skips the lede has read a commitment. ### Fees **Unblocked — Q4/Q14 answered, D14.** Build from the confirmed card in `docs/07-fees.md`. Plain table, no "starting from" evasions, no "contact for pricing" after promising a rate card. ### For parties The one page in second person. Grade-9 reading level. Short sentences. Says explicitly: **the mediator is a neutral and does not act for either party; each party should have their own legal advice;** and the mediator does not decide who is right. Answers what it costs and what happens if you do not settle. > ⚠️ **THIS DIRECTIVE READ *"the mediator is not your lawyer and cannot give you > legal advice"* UNTIL 2026-08-28, AND IT BREACHED D13 TWICE** — in the file that > warns, fifty lines above, that `/for-parties/` is *"the exact place the > 'cannot' phrasing feels most natural and is most wrong"*. > > 1. **"not your lawyer" presupposes lawyer status.** §4 Forbidden bars *the word > "lawyer" used of Pouya*, and D13 treats implication as hard as assertion. A > negation still carries the presupposition. > 2. **"cannot give you legal advice" is attempt 2** in this file's own ratified > table — *"a **denial** of capacity"* — and it fails test 3 and the > compliance-checklist item, both added to this file in the same change set > that left this line untouched. > > The replacement is the ratified pattern applied verbatim: **role, then > consequence for the reader, and no verb of capacity.** Found by > `claims-auditor` on re-audit; the original sweep did not reach this section. ### Insights 1,200–1,800 words, monthly cadence (brief §VIII). Territories from §VII: process explainers · regulatory commentary · industry dispute commentary · anonymised reflections · technical explainers for lawyers · credentialing content. Every piece links to at least one practice-area page. Anonymised reflections must be genuinely unidentifiable — not merely name-stripped. If a matter could be recognised by the parties to it, it does not run. ### Launch article slate (D9) Drafted by Claude, **every word reviewed by Pouya before publication**: 1. *What the Ontario data-centre build-out means for dispute resolution* — technology + construction; the strongest single differentiator piece. 2. *When Med-Arb is the right answer, and when it is not* — process explainer; feeds `/med-arb/`; high search intent, thin competition. 3. *Bill 40 and grid connection: a dispute-resolution read* — regulatory commentary; establishes the energy niche. 4. *What a System Impact Assessment actually evaluates* — technical explainer for lawyers; the clearest demonstration of the claim the whole brand rests on. 5. *Choosing a neutral: what counsel should actually ask* — evergreen, useful, and it makes the case for this practice without arguing for it. --- ## Compliance checklist — before any page ships - [ ] Every factual claim appears in `AGENTS.md` §4 Verified - [ ] No matter counts, settlement rates, dollar figures, or time-to-award stats - [ ] No testimonials, endorsements, or third-party quotes - [ ] No superlatives and no guarantee language - [ ] No claim or implication of legal licensure anywhere (D13) - [ ] Q.Arb described as commenced August 2026, never as held or nearly complete - [ ] Nothing implies a firm, a team, or offices that do not exist - [ ] Contact page states that an inquiry creates no retainer and no mediator–party relationship - [ ] Any comparative claim is factual and verifiable - [ ] No sentence answers the licence-capacity question in **either** direction — see *When a fact is `[unestablished]`* above. Check for *cannot*, *do not*, *am not*, *not permitted*, *not qualified* **attached to giving legal advice, practising law, or holding a licence.** The objection is to answering the *capacity* question, not to the words themselves — the approved sentence contains "do not" and passes: *"I act as a neutral. I do not act for a party in a matter I take, and each party should have their own legal advice."* That is **role conduct**, which he may state freely. *(This item shipped unscoped for one pass and `adversarial-reviewer` showed it would fail the exact sentence the section exists to bless — and the checklist is what gets grepped.)* - [ ] Abbreviations expanded on §11 Glossary's authority only — and expansions for the five ADR designations checked against `docs/reference/adrio-designations.md`, not from memory. "Chartered **Med**-Arbitrator", never "Mediator-Arbitrator"