In Gallo v. Getz (1988) 205 Cal. App. 3d 329, attorneys for both sides negotiated a settlement of a personal injury action. The plaintiff then refused to "go along" with the settlement, and he did not sign the settlement agreement or release documents. (Id. at p. 332.) However, the plaintiff did accept, endorse and deposit a bank draft from the defendant's insurer, which was sent as part of the consideration for settlement of the plaintiff's claim. (Id. at pp. 331-332.) Although the letter from the plaintiff's attorney memorializing settlement terms did not satisfy the requirements of section 664.6, the appellate court concluded the bank draft constituted a "writing" signed by the parties and hence was sufficient to support enforcement of the settlement under section 664.6. (Id. at pp. 333-334.)