How have courts interpreted the collateral source rule in determining whether to compel a plaintiff to produce the terms and conditions of their insurance settlement?

Below the plaintiffs relied heavily on the case of Norton v. Superior Court (1994) 24 Cal.App.4th 1750, 30 Cal.Rptr.2d 217. That case was a legal malpractice action in which clients sued the law firm which had handled the settlement of their suit for property damage against a city. The law firm sought production of all documents containing the terms and conditions of plaintiffs' recovery from their own insurer for the same property damage that was the subject of their suit against the city. Plaintiffs objected based on the collateral source rule, and the trial court denied the law firm's motion to compel on that basis. (Id. at pp. 1753, 1762, 30 Cal.Rptr.2d 217.) The appellate court ruled that [51 Cal.App.4th 238] although the collateral source rule made such evidence inadmissible at trial of the malpractice action, nevertheless broader rules govern discovery than admissibility of evidence at trial; hence it issued a writ requiring the trial court to reconsider its ruling, which had been based solely on the collateral source rule.