After negotiating an agreement for his client John, Attorney signs the agreement at the end stating that the agreement is “approved as to form and content.” A dispute arises between John and the other party, Mike. Now Mike sues John’s Attorney for fraud. Mike’s theory is that by approving the agreement as to form and content Attorney was making representations as to the accuracy of the agreement. Id. at 1068. The question before the court was: does (John’s) Attorney’s signature amount to an actionable representation to Mike?