After Arnold rear-ended Liggins, he admitted fault but disputed causation and damages. A jury awarded Liggins $70,000; the trial court also awarded $23,430 in attorney fees and litigation expenses under Georgia’s settlement-offer statute. Arnold challenged exclusion of a police report about Liggins’s prior accident, admission of a health-insurance claim form as a medical bill, closing argument seeking more lost earnings than listed in the pretrial order, and the fee award. The Court of Appeals affirmed the trial rulings: the police report’s hearsay narrative was inadmissible, and any error was harmless given other injury evidence; Arnold showed no reversible harm from the medical form or closing argument. It reversed the fee award. Liggins had recovered more than 125 percent of his $45,000 offer, but served it by email. The statute expressly required certified mail or statutory overnight delivery. Although a separate statute permits electronic service in some cases, the settlement statute incorporated it only as to service form, not method. Because email did not satisfy the required method, Liggins could not recover fees. The judgment was affirmed in part and reversed in part; Barnes and Land concurred.