A court of the Northern District of Texas granted summary judgment in favor of insurer under an all risks policy issued to a wholesale buyer of bullion coins and precious metals, finding that loss stemming from a gold heist by use of fraudulent checks, and subsequent rerouting of the delivery of gold coins to be intercepted by the fraudulent purchaser, was barred from coverage by operation of the policy's Invalid Payments Exclusion, which excluded coverage for handing over insured property "consequent upon" a fraudulent check, despite concurrent causes, and that insured's insurance code claims failed for the same reasons.
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