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4723 REVIEW DENIED While another unlitigated insurance claim was pending, an insurer's offer to settle an insured's bad faith lawsuit in return for a general release of "all claims" did not meet the requirements of Code of Civil Procedure section 998 because it would have settled and required the release of a claim that was not part of the lawsuit.CitationPO-JEN CHEN v INTERINSURANCE EXCHANGE (All Claims) 164 CA4 117 [See: CCP 1032, 998; CivC 1542; Valentino v Elliott 201 CA3 692; Barella v Exchange Bank 84 CA4 793, T/AT 12/00]
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