Members of the Bench and Bar discuss settling complex litigation and the issues to consider. Especially litigation that involves multiple cases in different jurisdictions with related regulatory proceedings and unique strategic concerns at every stage. The outline presents a number of issues that are relevant to settling such litigations: laying the groundwork for settlement, determining when to settle, deciding whether to negotiate a group settlement, establishing procedures--such as mediation--to guide the settlement process, considering creative solutions to settlement, and drafting settlement agreements.