Only the “Good Faith” Early Bird Gets the Worm

Licudine v. Cedars-Sinai Medical Center, 2018 DJDAR 70 (Ct. App. Jan. 3, 2019)

The Court of Appeal on January 3, 2019 provided us with guidance on when an unaccepted statutory offer made under California Code of Civil Procedure Section 998 will create exposure to the offeree to penalties for its rejection. While this case involves only California’s statutory scheme for offers to compromise, it may have important ramifications in addressing policy limit demands, as both involve issues of “good faith.”

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