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e-Mail Signature Ruled Valid To Enforce Settlement

By Joel Stashenko
September 02, 2013

Signing an e-mail attesting to the substance of a negotiated agreement with the typed name of the sender constitutes a binding and enforceable stipulation of the settlement under CPLR 2104, a New York state appeals panel ruled on July 26. See, Forcelli v. Gelco Corp.,' 27584/08, NYLJ 1202612381868, at *1 (App. Div., 2nd, Decided July 24, 2013).

An Appellate Division, Second Department, panel held unanimously that an agent for a vehicle insurer, by entering her name to the message summing up the terms of a settlement in an auto accident case, provided the “subscription” to the written statement required for an enforceable stipulation under CPLR 2104.

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