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p0693 DEPUBLISHED A pattern of bad faith can not be used as a basis for punitive damages in an insurance bad faith action, but evidence of such a pattern could strengthen plaintiff's bad faith claim, making it possible that discovery of information regarding prior claims will lead to relevant evidence; never the less, since such discovery would involve the privacy of claimants involved, a trial court should conduct a hearing to determine an appropriate procedure for plaintiff to obtain authorization from those claimants.CitationPERMANENT GENERAL ASSURANCE v SUPERIOR COURT (Claim Files Discovery) 122 CA4 1493 [See: CCP 2017; InsC 791 etseq; State Farm v Campbell 538 US 408, T/AT 7/03]
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