In Murray v. Home Benefit Life Ass'n. (1891) 90 Cal. 402, the insured failed to make two payments on his policy; the insurer then sent two letters to the insured, one asking him to pay the overdue amounts and one asking him to make the next scheduled payment. The court stated, "the letter notifying the insured that an assessment would be due and payable on October 1st, and in substance requesting payment, of itself constituted a waiver of the previous default, and must be construed as an unconditional offer to accept payment of that assessment on or before the date named. It was, in effect, an assertion that the certificate was still in force, and, notwithstanding previous defaults known to the defendant, would remain in force until the date therein named for such payment." (Id. at p. 408.)