Stereo v. Markusson

Trial court erred in denying motion for appellate attorney’s for the reason that plaintiff made a joint proposal for settlement to two defendants because prior case law holding such proposals were invalid were superseded by the addition of a provision to Florida Rule of Civil Procedure 1.442(c) in 2010 that specifically authorizes a joint proposal to two defendants where one of them is vicariously liable. Saterbo v. Markuson, 41 Fla. L. Weekly D2169 (Fla. 2d DCA Sept. 21, 2016).