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Florida Third DCA rules that service of proposal for settlement must comply with the email service requirement of Florida Rule of Judicial Administration 2.516

On February 15, 2017, in Wheaton v. Wheaton, No. 3D16-490, the Florida Third DCA affirmed a trial court’s ruling that a prevailing party was not entitled to attorney’s fees pursuant to a proposal for settlement because she had failed to comply with the e-mail service requirements of Florida Rule of Judicial Administration 2.516 in submitting the proposal for settlement to the opposing party. The Court noted that its ruling was in accord with the previous decisions from the First DCA and Fourth DCA.

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