Can a plaintiff who was not insured under section 1063.7, subdivision (b) of the California Insurance Commissioner's Notice of Action be served by mail?

In any event, even if appellants are not "insureds" within the meaning of section 1063.7, subdivision (b), they were still entitled to written notice under subdivision (a) as "persons known or reasonably expected to have or be interested in claims against the insurer." Appellants dispute the reasonableness[34 Cal.3d 139] of the Commissioner's decision to exclude pre-1974 policyholders from notice by mail. Supposedly, that decision was justified in large part by the fact that the statute of limitations on medical malpractice was four years (Code Civ.Proc., 340.5), but, as appellants correctly assert, the four-year period is not a reasonable cut-off date, since the statute of limitations can be extended or tolled for various reasons. ⁷ (See, e.g., Brown v. Bleiberg (1982) 32 Cal.3d 426, 432-433, 186 Cal.Rptr. 228, 651 P.2d 815.) Moreover, even an outlawed claim has to be defended. The duty to furnish such a defense--one of the obligations of the insolvent insurer--is assumed by CIGA under the express provisions of

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