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p0380 REVIEW DENIED An unapportioned offer of compromise to multiple defendants does not satisfy the requirements of Code of Civil Procedure section 998 because each may be liable for a different amount, and since the validity of the offer is determined as of the time it is made, such an offer is invalid even though the defendants subsequently stipulated that they were jointly and severally liable.CitationBURCH v CHILDREN'S HOSPITAL (Compromise Offer) 109 CA4 537 [See: CCP 998; CivC 3291; Taing v Johnson 9 CA4 579, T/AT 11/92; Bihun v AT&T 13 CA4 976, T/AT 4/93; Steinfeld v FooteGoldman 50 CA4 1542, T/AT 1/97]
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