See Bus &P C §6068 (e). In the previous case, the insurer had determined that it would not use its own billing documents to challenge the owners` attorneys` fees, and the insurer did not seek to recover its own attorneys` fees from the owners. Although an offer of settlement under Rule 167 could result in an application for counsel from the insurer, the court recognized that Rule 167 itself provides for a procedure for reopening the discovery so that a party can determine the appropriateness of the costs claimed.  In County of Los Angeles Board of Supervisors v. Superior Court (ACLU of Southern California),1 the Supreme Court of California held that solicitorial privilege does not categorically apply to information contained in attorneys` accounts unless the underlying legal case remains pending and active. . . .