This recent 2026 case Matthews v. Ryan (cited as 118 Cal.App.5th 155) poses an interesting question about CCP 998 offers and whether an offer that requires a condition to be met is invalid. Let me zoom out first to lay some foundation. Picture this: you serve a 998 on a defendant who is defended by an insurance carrier. You add a condition: "This offer is conditional upon defendant's insurance carrier consenting to defendant's acceptance of this offer." Defendant rejects.

Yesterday I formally announced my firm reopening on my LinkedIn. First, what a wave of positive energy and support from our incredible legal community. I love the support and look forward to continuing to give back to a community that gives so much. This morning I've been sitting with a piece of my post which is part of my tag line “Trained. Organized. Experienced.” Here's part of what I posted yesterday about this: “Organized: I have presented twice recently with Trial Guide

2026 has been a year of learning, as most years are for me. In my opinion, the absolute best way to represent my clients and tell the story of how the defendants acted poorly and how that action harmed my clients is to do the trainings that the defendants did or should have done. With this, I spent four weeks doing an accredited program through United Trucking in San Diego, which is designed to become a commercial truck driver. This class was intense, as it was a full-time jo