In Robertson v. Chen (1996) 44 Cal.App.4th 1290, the defendants' mandatory settlement conference (MSC) statement, signed by an attorney, stated that a defense settlement offer would remain open until trial. When the plaintiffs later attempted to accept the offer, the defendants claimed it had been revoked. (Id. at pp. 1291-1292.) The Court of Appeal concluded the plaintiffs could not summarily enforce the settlement using section 664.6 because the MSC statement was signed only by counsel for one side. (Id. at p. 1293.) However, the court went on, in a lengthy discussion not essential to disposition of the case, to express the view that special considerations warrant a relaxation of Levy's party-signature requirement when a party is represented by insurance counsel and the carrier is providing defense and indemnity without a reservation of rights. (Id. at pp. 1293-1296.) When an insurer undertakes to provide a defense and pay indemnity without reservation, the Robertson court reasoned, the insurer's decision to settle within policy limits "does not prejudice the 'substantial rights' of the insured." (Id. at p. 1294.) In such cases, in which the insured party is generally precluded from interfering with the carrier's settlement negotiations, Robertson opined that the "superfluous" signature of an insured should not be necessary to render the agreement enforceable under section 664.6. (Id. at pp. 1294-1295.)