Footnote 202

Magistrate Judge Edward M. Chen of the U.S. District Court for the Northern District of California has commented that "[e]mployment cases, as a class, are more difficult to settle than almost any other that appear on the federal docket." He then proceeds to explain: "Because the issues are highly personal and because parties are often unwilling to give up any ground, the cases are often very difficult to resolve even when the[y] should." Judges Counsel Attorneys to Settle Cases, Deal With Confidentiality, Privacy Concerns, 18 Empl. Discrim. Rep. (BNA) 384, at 384 (Mar. 27, 2000).