A "Special Master" or "master" is generally a private individual appointed by a court to carry out an express directive on its or the parties' behalf in a pending action. New York courts commonly employ Special Masters to carry out a variety of express tasks in civil cases. In complex litigation, the use of Special Masters, or referees as they are sometimes called in New York state court, is pervasive and can be strategically utilized to the benefit of the parties and the court alike.