The following excerpt is from Polcyn v. Liberty Mut. Ins. Co., Civil No. 12cv730-CAB (BGS) (S.D. Cal. 2013):
1. An insured suing in tort may recover "those attorney's fees that were incurred to obtain the policy benefits and that would not have been incurred but for the insurer's tortious conduct." Brandt v. Superior Court, 37 Cal.3d 813, 819 (1985).
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