<Any sealed settlements will imply we negotiated from a weak position.>

I do not agree with that statement. I would think that a necessary precursor to getting both sides to accept a Special Master, would be to have any settlement sealed.

Whatever the Special Master puts in his report to the court, can be read to a jury. And one of his duties is.

<(4) The relief claimed, including a particularized itemization of all elements of
damages which may reasonably be claimed based upon the evidence which
would be presented at trial; >

Hence, the odds are extremely high that there would be a settlement prior to making those recomendations to the court.

IMO, Opty