On January 4, 2019, in Wheaton v. Wheaton, No. SC17-716, the Florida Supreme Court resolved a split between the Florida Third DCA and several other Florida DCAs, concluding that proposals for settlement submitted pursuant to section 768.79, Florida Statutes (2018), and Florida Rule of Civil Procedure 1.442 need not comply with the email service provisions of Florida Rule of Judicial Administration 2.516.
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