Printed Name At The Bottom Of Several E-mails 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 coupled 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 e-mails 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].)