Judge: Laura A. Seigle, Case: BC708543, Date: 2022-07-26 Tentative Ruling
Case Number: BC708543 Hearing Date: July 26, 2022 Dept: 15
[TENTATIVE] ORDER RE MOTION TO COMPEL SETTLEMENT
PAYMENT
Plaintiffs
seek an order under Code of Civil Procedure section 664.6 compelling
Bristol-Meyers Squibb to make a settlement payment pursuant to a January 9 or
January 14, 2022 settlement agreement.
Plaintiffs state the settlement agreement required the settlement to be
funded no later than 45 days from the receipt of an executed release, but they
have yet to receive the payment. (Motion
at p. 3.)
There are several
problems with this motion. First,
Plaintiffs did not file a copy of the January 9, 2022 settlement agreement or
January 14, 2022 settlement agreement. The
party seeking to enforce a settlement “must first establish the agreement at issue
was set forth ‘in a writing signed by the parties’ (§ 664.6) or was made orally
before the court. [Citation.]” (Harris v. Rudin, Richman & Appel (1999)
74 Cal.App.4th 299, 304.) Without the
actual agreement at issue, the Court cannot determine the parties to the
settlement or which agreement (January 9 or January 14 or both) is the
pertinent settlement agreement. This is critical
because Bristol-Myers asserts it did not sign the settlement agreement. Plaintiffs state the agreement is
confidential. If so, Plaintiffs should
follow the procedure set out in California Rule of Court, rule 2.551 by filing
a motion for an order to seal the record or by filing a notice of the lodging
of the confidential document.
Second,
under section 664.6, if the parties “stipulate, in a writing signed by the
parties outside of the presence of the court . . . for settlement of the case .
. . the court, upon motion, may enter judgment pursuant to the terms of the
settlement. Strict compliance with the statutory
requirements is necessary before a court can enforce a settlement agreement. (Sully-Miller Contracting Co. v. Gledson/Cashman
Construction, Inc. (2002) 103 Cal.App.4th 30, 37.) Without a copy of the settlement agreement,
the Court cannot determine the terms of the settlement agreement to enforce and
enter judgment upon.
Third,
Plaintiffs did not file evidence that they executed a release and delivered it
to Bristol-Meyers, which according to Plaintiffs’ motion is a condition of
Bristol-Meyers paying the settlement money.
If this is a condition (which the Court cannot determine because it does
not have a copy of the settlement agreement), the Court cannot require payment
if this condition has not been satisfied.
The
motion is DENIED.