In Bachman v. Independence Indemnity Co. (1931) 112 Cal.App. 465, the insurer issued an automobile liability policy to Katie Bachman. ( Id., at p. 467.) Any permissive driver was treated as an additional insured. ( Id., at p. 469.) The policy required "the insured" to give the insurer "immediate written notice" of any accident and send the insurer any pleading or other paper relating to a claim. ( Id., at p. 472.) While Forest Bayliss was driving Bachman's car, with her permission, there was an accident in which Bachman was killed. ( Bachman v. Independence Indemnity Co., supra, 112 Cal.App. at p. 467.) Bachman's estate filed a wrongful death action against Bayliss. ( Id., at pp. 467-468.) The attorney for the estate sent a copy of the summons and complaint in the wrongful death action to the insurer. The insurer refused to defend Bayliss and denied any liability to Bachman's estate. After a default judgment was entered against Bayliss, Bachman's estate filed a direct action against the insurer in which it recovered the amount of the judgment. ( Id., at p. 468.) On appeal, the insurer argued it was not liable because Bayliss had not given it notice of the accident or of the wrongful death action. ( Bachman v. Independence Indemnity Co., supra, 112 Cal.App. at p. 469.) The appellate court held that the summons and complaint forwarded by the attorney for Bachman's estate constituted "sufficient notice." ( Id., at p. 470.)