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ARTICLE · 28 AUGUST 2025

Uneven Ground: Pro Se Litigants Facing Represented Parties

Beresford Booth
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The Washington Court of Appeals' decision, Zhi Feng v. Xiaoqiang Wu et al., addressed such a situation.

United StatesReal Estate and Construction
Zachary M. Smith
Zachary M. Smith
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The Washington Court of Appeals' decision, Zhi Feng v. Xiaoqiang Wu et al., addressed such a situation. In Feng, a real estate broker represented himself in a lawsuit and subsequent settlement negotiations following a failed real estate deal. Ultimately, the real broker ended up with some costly unintended consequences. Misunderstanding the language and terminology used in legal documents can result in costly consequences.

The Court of Appeals affirmed the enforcement of a settlement agreement under Washington Court Rule ("CR") 2A between real estate broker Z. Feng and defendants V. Veresko and T. Cowin. CR 2A governs the enforceability of settlement agreements. Generally speaking, CR 2A agreements are used by attorneys in situations where their clients have agreed on broad terms regarding their dispute but still need to iron out the finer points of their settlement agreement. Per CR 2A, Washington courts will only recognize such agreements if made in an open court

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