of settlement negotiations, not the settlement itself. See Fed. R. Evid. 408(a)(1) (“Evidence of the following is not admissible on behalf of any party, when offered to prove liability for, invalidity of, or amount of a claim that was disputed as to validity or amount, or to impeach through a prior inconsistent statement or contradiction: ... furnishing or offering or promising to furnish — or accepting or offering or promising to accept — a valuable consideration in compromising or attempting to compromise the claim.”). So Steele and Vardon are not evidence of a privilege preventing discovery of settlement agreements — instead they caution against discovery of settlement discussions. Goodyear, while decided in the Sixth Circuit, essentially says the same thing, 332 F.3d at 981-82 (<HOLDING>). Although it formally accepted the settlement
recognizing the opportunity for mischief in settlement negotiations where the insurer has declined involvement  which may be checked by judicial review of whether the settlement amount stipulated to is reasonable holding that in the context of a settlement contract the defrauded party may either 1 rescind the settlement or 2 ratify the settlement retain the proceeds and institute an action to recover fraud damages holding that a settlement agreement is not a court order and therefore a violation of the settlement agreement would not subject a party to contempt holding a settlement privilege exists as to thirdparty discovery of settlement negotiations holding that an insurer acted in bad faith by failing to keep the insured informed of settlement negotiations