available for breach of the implied covenant of good faith and fair dealing in an employment contract. Moradi-Shalal v. Fireman’s Fund Ins. Cos., 46 Cal.3d 287, 758 P.2d 58, 250 Cal.Rptr. 116 (1988), revived the common sense rule that third parties cannot sue insurers for unfair insurance practices, overruling Royal Globe Ins. Co. v. Superior Court, 28 Cal.3d 880, 592 P.2d 329, 153 Cal.Rptr. 842 (1979). But much remains to be done. As this case demonstrates, Seaman’s is a prime candidate for reconsideration. Others come to mind: Pacific Gas & Elec. Co. v. G.W. Thomas Drayage & Rigging Co., 69 Cal.2d 33, 442 P.2d 641, 69 Cal.Rptr. 561 (1968) (rejecting the notion that a contract can ever have a plain meaning); Casey v. Proctor, 59 Cal.2d 97, 109, 378 P.2d 579, 28 Cal.Rptr. 307 (1963) (<HOLDING>); and April Enters., Inc. v. KTTV, 147
holding that release discharges only persons named in or sufficiently described by terms of release holding that a release of unknown claims has no effect in the absence of evidence apart from the words of the release holding that for purposes of revoking supervised release the applicable guidelines are those in effect at the time of the supervised release violations rather than those in effect at the time of initial offense holding that inclusion of a general release was merely a suggestion of how to terminate the lawsuit and that acceptance was not qualified on use of the specific release and party was willing to discuss the terms of a release holding that release discharges only those tortfeasors specifically named in the release agreement