In Vega v. Western Employers Ins. Co. (1985) 170 Cal.App.3d 922, the court examined a release document executed in a personal injury action. Plaintiff Vega was injured in a vehicle accident, suing the other driver and vehicle owner and recovering a judgment. The then plaintiff settled with the other driver and owner and their insurer, Western, releasing all claims, known or unknown, which arose "from the accident," and waiving section 1542 protections. (Vega, supra, 170 Cal.App.3d at p. 924.) The issue arose whether the plaintiff's subsequent separate action against the insurer for unfair practices, claiming bad faith refusal to settle, should be barred by the release. The court did not find any reference in the release to potential liability of the insurer with respect to different theories of recovery, such as bad faith, unfair practices, or Insurance Code section 790.03. The only consideration given was for the release of the personal injury claims arising from the accident, not the bad faith claims. "Thus, we conclude the purpose for the inclusion of Western's name in the release is ambiguous and remains a factual question. Accordingly, parol evidence was and is admissible on the question of the parties' intent. And regardless of the language in a form release, there are few, if any, occasions where the issue of the releaser's intent is not one of fact." (Vega, supra, at pp. 926-927.)