Email Signature Ruled Valid to Enforce Settlement

“An Appellate Division, Second Department, panel held unanimously that an agent for a vehicle insurer, by entering her name to the message summing up the terms of a settlement in an auto accident case, provided the “subscription” to the written statement required for an enforceable stipulation under CPLR 2104… Justice Sandra Sgroi, writing for the panel in Forcelli v. Gelco Corporation, 27584/08, said that typing the sender’s name at the end of an email accomplishes the same purpose of validating the stipulation that signing a paper document by hand does under CPLR 2104.”