New York Law Journal "Oral Settlement Agreement: Read It Into the Record" by Thomas Dewey
"As discussed in the most recent edition of this column, the U.S. Court of Appeals for the Second Circuit, in Winston v. Mediafare Entertainment, has recognized that an unexecuted settlement agreement may still be enforceable. Although this rule certainly allows for an oral settlement agreement to be binding on the parties to a litigation, a recent New York district court case suggests that the hurdle remains high for an oral settlement agreement to satisfy the Winston standard."
