Defense Ignoring Of Offer And Equitable Estoppel Defense Did Not Prevail.
Plaintiff's CCP § 998 offer was found to be invalid by both the lower and appellate courts in Bigler-Engler v. Breg, Inc., Case No. D063556 (4th Dist., Div. 1 Jan. 6, 2017) (partially published; 998 discussion published) based on the failure to include a mandatory "acceptance" line for signature by the defense. Plaintiff argued that the defense ignoring of the offer (ultimately, rejecting it) and equitable estoppel principles dictated another result, but this was found not to alter the conclusion that the 998 offer was invalid in nature by failure to include an acceptance line for signature.