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P1482 In an action against an insurer for breach of contract and breach of the implied covenant of good faith and fair dealing, an issue relating to fees incurred by the insured for independent Cumis counsel must be submitted to arbitration under Civil Code section 2860, but issues falling outside the scope of that statutory requirement may be adjudicated by the court.CitationCOMPULINK v ST PAUL FIRE AND MARINE (Cumis Arbitration) 169 CA4 289 [See: CivC 2860; SD Federal CU v Cumis 162 CA3 358; Long v Century 163 CA4 1460, T/AT 7/08]
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