In Phelps v. Kozakar (1983) 146 Cal. App. 3d 1078, two companion cases settled after a mandatory settlement conference. ( Id. at p. 1081.) The stipulation regarding the settlement, placed on the record, provided that Estrella, the plaintiff in one of the lawsuits would dismiss with prejudice the action against Phelps. ( Id. at p. 1081.) The stipulation also called for Estrella and his wife, who was not a party to the action, to execute a promissory note secured by a deed if trust in the Estrella's property and provide a grant deed conveying interest in property owned by the Estrallas to Phelps. ( Id. at p. 1081.) The court held that Estrella's wife was bound to the terms of the settlement even though she was not a party to the action. ( Phelps v. Kozakar, supra, 146 Cal. App. 3d at p. 1083-1084.) It reasoned that "it is of no moment she was not a party to either action; she had an interest in the subject matter of the litigation and in fact participated . . . in the proposal to change the terms of the agreed-upon settlement." The court also held that Estrella was bound by the terms of the settlement agreement and had received consideration because he "desired to assist his longtime friend and associate, John Kozakar, who could not pursue further business ventures so long as these actions were pending." ( Id. at p. 1083.) Under Phelps, a person can be bound by the terms of a settlement agreement even if the person is not a party to an action.