Clayton United Servs. Auto Ass’n, 54 Cal. App. 4th 1158 (1997)(insurance company offered $10,000 on policy limits of $300,000 to parents whose only child was killed in an automobile accident); White v. Western Title Ins. Co., 40 Cal. 3d 870 (1985)( low settlement offers made in course of bad faith litigation). Note California Fair Claims Settlement Practices Regulations on this subject.