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ARTICLE · 15 SEPTEMBER 2025

Richard Bartel v. Chicago Title Insurance Company

Lewis Brisbois Bisgaard & Smith LLP
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(September 2025) - In a long running dispute involving repeated tenders of defense of actions to quiet title for an easement running across Chicago Title Insurance Company's ("Chicago") insured...

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Michael Velladao
Michael Velladao
Monica Kalunian
Monica Kalunian
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(Failure to Consider Extrinsic Information in Support of Repeated Tenders of Defense of Quiet Title Actions Supported Claim for Bad Faith)

(September 2025) - In a long running dispute involving repeated tenders of defense of actions to quiet title for an easement running across Chicago Title Insurance Company's ("Chicago") insured, Richard Bartel's ("Bartel") property, the Court of Appeal in Bartel v. Chicago Title Ins. Co., 111 Cal.App.5th 655 (May 30, 2025) affirmed the trial court's holding that Chicago had acted in bad faith in refusing to defend Bartel against such actions. However, the Court of Appeal affirmed the trial court's decision that Chicago's conduct did not support an award of punitive damages.

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