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ARTICLE · 25 SEPTEMBER 2025

Did You Settle That Lawsuit? Are You Sure?

A "CR 2A agreement" refers to Washington Superior Court Civil Rule 2A (SEE HERE). This rule means courts will enforce a settlement when it meets certain criteria...

United StatesLitigation, Mediation & Arbitration

A "CR 2A agreement" refers to Washington Superior Court Civil Rule 2A (SEE HERE). This rule means courts will enforce a settlement when it meets certain criteria, even when the lawyers have not yet drafted a complete and detailed settlement agreement.

Lawyers in Washington state must exercise great care when they discuss settlement in writing. CR 2A agreements bind parties once key markers are present, and a simple email exchange can create an enforceable deal. Lawyers also must take caution not to enter such agreements by accident, because courts will uphold them if the terms appear clear and intentional.

In a case decided by the Washington Court of Appeals last week, the court enforced a settlement between Omni Staffing Services, Inc., and healthcare facilities owned by Caldera Partners Limited Partnership. Omni provides temporary staff to health care providers. Caldera owed Omni about $291,000 for unpaid invoices. Caldera sent a $50,000 partial payment, and

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