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1876 REVIEW DENIED A court can enforce an arbitration award if the parties voluntarily proceeded to arbitration without a written agreement to arbitrate; a party who has stipulated on the record that it is willing to be bound by arbitration may be judicially estopped from subsequently claiming that the court's order to arbitrate was invalid for lack of a written agreement.CitationHERZOG v FREDRICS (Arbitration Stipulation) 61 CA4 672 [See: CCP 1280 etseq, 1141.10 etseq; Horn v Gurewitz 261 CA2 255; Soule v GM 8 C4 548, T/AT 11/94; Prilliman v United 53 CA4 935, T/AT 5/97]
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