"Insured v. Insured" Exclusion Precludes Coverage for Officers and Directors in Chapter 11 Bankruptcy Proceeding

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Debtors in a Chapter 11 reorganization may have a more difficult time recovering insurance proceeds on claims asserted against former officers and directors. Biltmore Associates v. Twin City Fire Ins. Co., _ F.3d _ (9th Cir. July 10, 2009).

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