MICHAEL D. MARCUS’S MEDIATION MESSAGE NO. 92 EARLY SETTLEMENT DEMANDS AND AN INSURER’S DUTY TO SETTLE Reid v. Mercury Ins. Co. (2013) 220 Cal.App.4th 262 provides that an insurer has no duty to settle with a third party, and thus no liability to its insured for the bad faith failure to settle, until there has been a settlement demand or “any other manifestation the injured party is interested in settlement.” (Id. at p. 266.) Absent…