In Thompson v. California Fair Plan Assn. (1990) 221 Cal. App. 3d 760, the plaintiff sued an insurer and obtained a declaratory judgment reforming a policy to name her as the insured. She then sued the insurer and a claims manager for conspiracy to deprive her of the insurance benefits. The court held the statute of limitations on the suit against the claims manager was not tolled by the prior suit against the insurer: "Here the claims manager was not named in the first suit for declaratory relief. It is difficult to imagine how he could have been alerted to the need to investigate the facts of the second claim." ( Id. at p. 765.)