What is the test for making a "reasonable offer" under section 998 of the California Vehicle Code?

A section 998 offer must be reasonable under the circumstances of the case. (Elrod v. Oregon Cummins Diesel, Inc. (1987) 195 Cal.App.3d 692, 696 (Elrod).) "Whether a section 998 offer is reasonable must be determined by looking at circumstances when the offer was made." (Id. at p. 699.) Courts generally assess reasonableness in two steps: first, "whether the offer represents a reasonable prediction of the amount of money, if any, defendant would have to pay plaintiff following a trial, discounted by an appropriate factor for receipt of money by plaintiff before trial," and

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