AROK Const. Co. v. Indian Const. Servs., 848 P.2d 870, 878 (Ariz.Ct.App. 1993) (emphasis added).

. A binding agreement “must be definite and certain so that the liability of the parties may be exactly fixed.” Rogus v. Lords, 804 P.2d 133, 136 (Ariz. App. Ct. 1991); see AROK Const. Co. v. Indian Const. Services, 848 P.2d 870, 877 (Ariz. App. Ct. 1993) (“Only ‘[i]f the essential terms are so uncertain that there is no basis for deciding whether the agreement has been kept or broken' does a contract not exist.”

(citation omitted); AROK Constr. Co. v. Indian Constr. Services, 174 Ariz. 291, 297 (App. 1993) ("[A]bsent or uncertain terms are not fatal to the enforceability of an otherwise binding contract."). Because the Barretts sought only to compel arbitration in the 2022 case, we need not decide whether they could assert a cognizable claim for breach of the mediation settlement agreement, or a claim for its specific enforcement, and nothing in this decision or in the 2019 decision precludes such claims.

(citation omitted); AROK Constr. Co. v. Indian Constr. Services, 174 Ariz. 291, 297 (App. 1993) ("[A]bsent or uncertain terms are not fatal to the enforceability of an otherwise binding contract."). Because the Barretts sought only to compel arbitration in the 2022 case, we need not decide whether they could assert a cognizable claim for breach of the mediation settlement agreement, or a claim for its specific enforcement, and nothing in this decision or in the 2019 decision precludes such claims.

at *36 (D. Ariz. Mar. 14, 2023) (citing AROK Const. Co. v. Indian Const. Servs., 848 P.2d 870, 878-79 (Ariz.Ct.App. 1993)). “[P]romissory estoppel applies where the defendant has made a promise that the plaintiff actually relied upon, to his detriment, and where it was reasonably foreseeable that the plaintiff would [justifiably] rely.

Minutes from the settlement conference indicate that Sierra Pines' counsel "advised the Court of the agreement as set forth on the record" and the court "noted for the record all parties knowingly, intelligently and voluntarily [had] reached an agreement," directing Sierra Pines' counsel "to draw up the agreement for signature." See AROK Constr. Co. v. Indian Constr. Servs., 174 Ariz. 291, 299 (App. 1993) ("Manifestations of assent that are in themselves sufficient to conclude a contract will not be prevented from so operating by the fact that the parties also manifest an intention to prepare and adopt a written memorial thereof ...." (quoting Restatement (Second) of Contracts § 27 (1981))).

. . .is not present.” AROK Constr. Co. v. Indian Constr. Servs., 848 P.2d 870, 878 (Ariz.Ct.App. 1993); Kersten v. Cont'l Bank, 628 P.2d 592, 595 (Ariz.Ct.App. 1981).

Because any differences between the Post-It note images are immaterial, Husband did not commit a fraud on the court. See AROK Const. Co. v. Indian Const. Servs., 174 Ariz. 291, 297-98 (App. 1993) (noting that the omission of nonmaterial terms does not preclude the creation of a contract and is not "fatal to the rights of the parties to obtain enforcement of their bargain"); cf. McNeil, 236 Ariz. at 178, ¶ 23 (observing that although "a false statement under oath about a matter in dispute may subject that party to sanctions," "[a] false statement to the court about a matter in dispute rarely will constitute a fraud on the court").

A contract is not sufficiently specific if it provides no basis to determine breach or fashion a remedy. AROK Const. Co. v. Indian Const. Services, 174 Ariz. 291, 297-98 (App. 1993) (citing RESTATEMENT (SECOND) OF CONTRACTS § 33(2) (1981)).

In Arizona, promissory estoppel may be pleaded as an alternative to a breach of contract claim. AROK Const. Co. v. Indian Const. Servs., 848 P.2d 870, 878-79 (Ariz.Ct.App. 1993) (“AROK also claims that it is entitled to relief based upon promissory estoppel. We hold that this is a proper claim for relief as an alternative to the contract claim.”).