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Fourth District Court of Appeal reverses trial court's finding that party's proposal for settlement was ambiguous and unenforceable

On January 4, 2017, in Kiefer v. Sunset Beach Investments, LLC, No. 4D16-707, the Fourth DCA reversed a trial court's finding that a defendant's proposal for settlement in a professional negligence case was unenforceable because it was fatally ambiguous. The Fourth DCA ruled that the proposal's failure to mention the defendant by name in every paragraph did not render the proposal defective when it was clear from the context that every paragraph related solely to the defendant and the plaintiff and not to any of the codefendants.