Suh

*255 INTRODUCTION

Allstate Insurance Company and several related companies (collectively, Allstate) brought this action under Insurance Code section 1871.7 ( section 1871.7 ) on behalf of the People of the State of California against Christine Suh, Christina Chang (Suh's mother), and others for insurance fraud in violation of Penal Code section 550 ( section 550 ), which makes it unlawful to submit false or fraudulent claims to an insurance company. Allstate alleged Suh set up sham law firms, then with Chang's help procured automobile insurance policyholders *502 of Allstate as clients of the sham law firms, submitted insurance claims on behalf of the insureds, and absconded with settlement proceeds. The jurors found in favor of Allstate and imposed over $6 million in civil penalties.

Suh appeals from the ensuing judgment, arguing the trial court should have stayed this action pending the resolution of a criminal investigation of her conduct. Suh, joined by Chang, also argues that the insurance claims they submitted to Allstate were not fraudulent because, although the insureds were not actually represented by attorneys, the information in the claims forms was accurate. We…