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We have been appointed to assist courts across the country and the parties in various roles:

  • Settlement Special Master

    • Experience with facilitating, negotiating, and implementing various settlement models (e.g., class actions, non-class “global”, inventory, individual settlements) tailored to address the parties’ needs and case-specific factual, legal, and practical issues.

    • Post-settlement review and evaluation of claims to allocate fairly aggregate settlements among participating claimants using clear, transparent methodologies.

  • Special Master for Management of Pretrial Litigation

    • Work with courts and parties to develop processes and procedures for orderly and efficient discovery of large volumes of cases simultaneously (e.g., bellwether and wave cases).

    • Conduct meet and confer conferences among parties to resolve discovery disputes.

    • Experience addressing complex legal issues through Reports & Recommendations (e.g., summary judgment, Daubert, federal preemption). 

  • Common Benefit Special Master

    • Coordinate with Common Benefit Committees early in litigation to establish guidelines and processes for regular, standardized time and expense submission.

    • Manage litigation budget, capital contributions, and common benefit expenses. 

    • Post-settlement review of common benefit submissions to determine a fair and equitable distribution of common benefit funds among plaintiffs’ counsel.

  • Conduct mediations for individual cases, small groups of cases, inventories, and mass litigations.

  • Experience in a variety of types of cases, including product liability, personal injury, and consumer class actions.

  • Evaluate and counsel clients regarding liability risks of complex mass litigation as part of due diligence and evaluation of potential investments or acquisitions.

  • Provide consultation regarding litigation risk mitigation strategies (e.g., teaching responsible business communications and conduct), litigation resolution strategies, and potential settlement structures.

  • Advise clients regarding Medicare Secondary Payer Act compliance.


Over fifty years of collective experience representing companies as settlement counsel in drug, medical device, and toxic tort litigation.

  • Craft and implement comprehensive litigation and settlement strategies to achieve client goals for global resolution while remaining flexible given changes in client needs and evolution of litigation landscape.  

  • Extensive experience negotiating and drafting settlement documentation, obtaining necessary court approvals, and efficiently implementing settlements, including addressing common settlement issues such as bankruptcy, probate, lien resolution, and compliance with Medicare reporting and other obligations.

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