may completely satisfy its liability by paying that sum, the claim letter satisfies the sum certain requirement. ¶ 13 Glendale contends that like the sum requested in Deer Valley, Yollin’s $150,000.00 offer of settlement was not a sum certain. We disagree. The claimant in Deer Valley used ambiguous language, describing the damages in “approximate! ]” terms, and never reaching a single aggregate sum. 214 Ariz. at 296, ¶ 10, 152 P.3d at 493 (emphasis omitted). Equally important, when the claimant stated a figure, she noted she may actually hold out for “more.” Id. (emphasis omitted). “[H]er damages for emotional distress and harm to her reputation [were] ‘no less than’ $300,000 and $200,000, respectively.” Id.; cf. Fields, 219 Ariz. at 90, 193 P.3d at 784, 2008 WL 1796039, at *1-2, ¶ 3 (<HOLDING>) (emphasis omitted). The letter in Deer Valley
holding that apprendi does not apply where the defendant was sentenced to less than the statutory maximum holding less than twothirds of the stock holding that gross sales of less than 5000 to fewer than 50 customers were below the minimum threshold for market penetration holding that jury could properly conclude that a 37foot 1980 hunter sailboat less than one year old had a value greater than 100 holding that demands for benefits not less than 10 million dollars contributions greater than 50 million dollars and less than 100 million dollars and attorneys fees not less than 150000000 were ambiguous and did not satisfy the sum certain requirement