Smith L. Watkins v. Richard Corbett, Jennifer Corbett, and Britannia Building Consultants of Pasco County, Inc.
The court affirmed the denial of Watkins's attorney's-fee motion, holding that a joint proposal for settlement that fails to apportion the amount attributable to each offeree is invalid under Florida Rule of Civil Procedure 1.442(c)(3). It held there is no tenancy-by-the-entireties exception to the apportionment requirement and expressly disagreed with the Fourth District's contrary decision in Mackensen v. Trace Elements.
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