SACRAMENTO, Calif. - A California federal judge on Nov. 27 concluded that "under California law, the duty of an insurer to effectuate settlement requires more than merely doing nothing while awaiting a formal written settlement demand," leading the judge to mostly deny a primary insurer's motion for summary judgment on an excess insurer's bad faith claims against it (Travelers Indemnity of Connecticut, et al. v. Arch Specialty Insurance Co., No. 2:11-cv-01601, E.D. Calif.; 2013 U.S. Dist. LEXIS 169453).