Printed Name At The Bottom Of An Email Not Enough To Show There Was A Settlement.

Plaintiffs filed a motion pursuant of Code of Civil Procedure section 664.6, to enforce a settlement. In concluding there was a settlement, the trial court found e-mails couple with a voice mail qualified as an electronic signature under the Uniform Electronic Transactions Act [Civil Code section 1633.1, et seq.; UETA]. The Court of Appeal reversed, concluding one party’s printed name at the bottom on one among many emails did not qualify under either Code of Civil Procedure section 664.6, or Civil Code section 1633.7, to effectuate a settlement. (J.B.B. Investment Partners, Ltd. v. Fair (Cal. App. First Dist., Div. 2; December 5, 2014) 232 Cal.App.4th 974, [182 Cal.Rptr.3d 154].)