On May 9th and 10th, 2019, Ray Gates attended the USAA California Defense Counsel Summit in Phoenix, Arizona. The Summit included discussion of the current trends in California law and venues. While at USAA, Ray gave a presentation to USAA managers and adjusters regarding the handling of conditional demands and a reasonable approach to responding to time limit conditional demands. They also discussed the recent holding in Licudine v. Cedars-Sinai Medical Center regarding evaluating cases when an Offer of Judgment has been served.