California, United States of America
The following excerpt is from Pacific-Southern Mortgage Trust Co. v. Insurance Co. of North America, 166 Cal.App.3d 703, 212 Cal.Rptr. 754 (Cal. App. 1985):
Finally, the award of attorney's fees was proper (see Brandt v. Superior Court, 37 Cal.3d 813, 819, 210 Cal.Rptr. 211, 693 P.2d 796) to the extent they are attributable to efforts to obtain the payments withheld in bad faith. The record does not show the attorney's fees were awarded for any other purpose.
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