The panel will discuss the timing of when to settle, including factors relating to the maturity of the litigation, purchase/sale of companies or units, state or federal investigations, and the scope and importance of confirmatory discovery in early settlement negotiations. The panelists intend to discuss settlement relief and alternatives to cash compensation. The parties can discuss the criteria for the selection of, use of, and timing for the request for an appointment of a Special Settlement Master. The Special Settlement Master can talk about the value that using a Special Settlement Master can bring to a process, including, for example, the value in protecting the integrity of the settlement negotiations, reaching agreement on attorneys’ fees and costs, eliminating or at least blunting objections relating to arms-length negotiations, communications with the Court, and client counseling for defendants.

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