In Golden Eagle Ins. Co. v. Foremost Ins. Co. (1993) 20 Cal. App. 4th 1372, 1395-1396 25 Cal. Rptr. 2d 242, the insurer provided its insured with a defense without a reservation of rights. Because there was no reservation of rights, the insureds would not normally be entitled to independent counsel under Cumis or section 2860. But the court found that a conflict arose when the insurer's defense counsel, over the insureds' objections, attempted to negotiate a settlement in excess of policy limits, and that settlement would have exposed the insureds to claims by tenants who were not plaintiffs in the underlying action. Defense counsel's attempt to negotiate a settlement in excess of policy limits rendered his representation of the insureds "less effective" and, consequently, the insureds were entitled to advice from independent counsel regarding settlement. In Golden Eagle, the insurance counsel's representation of the insurance company's interest made his representation of the insureds "less effective," because it exposed them to claims by third parties. Moreover, "one set of clients--the insurers--was seeking to settle the case with the other clients' money." (Golden Eagle Ins. Co. v. Foremost Ins. Co., supra, 20 Cal. App. 4th at p. 1396.)