California, United States of America
The following excerpt is from Pacific Nat. Ins. Co. v. Superior Court (Liptak), 198 Cal.App.3d 274, 233 Cal.Rptr. 189 (Cal. App. 1986):
Except in rare cases, the "conclusion" requirement presents no problem. Here, for example, there was a settlement of the third party action, a release was given and a dismissal with prejudice was filed. Thus, the third party action has been concluded. (Rodriguez v. Firemen's Fund Ins. Co., supra, 142 Cal.App.3d 46, 53-55, 190 Cal.Rptr. 705; cf. Afuso v. United States Fid. & Guar. Co. (1985) 169 Cal.App.3d 859, 863, 215 Cal.Rptr. 490.)
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