Reasonableness of the Conditions for Settlement
A unilateral payment without such a release would not constitute a settlement of the claim and might in fact bankroll continued litigation. (State Farm Mut. Auto. Ins. Co. v. Crane (1990) 217 Cal. App. 3d 1127, 1136 266 Cal. Rptr. 422; Croskey et al., Cal. Practice Guide: Insurance Litigation, supra, P 12:303, p. 12B-22).
"An insurer may, within the boundaries of good faith, reject a settlement offer that does not include a complete release of all of its insureds." ( Strauss v. Farmers Ins. Exchange (1994) 26 Cal. App. 4th 1017, 1021 31 Cal. Rptr. 2d 811.)