Appellants challenged an award of attorneys' fees and costs against them, which was based on a proposal for settlement. The District Court of Appeal reversed, because the terms of the proposal were not clear. A proposal for settlement must be as specific as possible. This will allow the receiving party to fully evaluate its terms and conditions. The terms of the release upon which the settlement offer is conditioned must be stated with sufficient particularity in the proposal to allow full appraisal of the offer.