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National Liability & Fire Insurance Co. v. Young

Court: ND Tx  05/12/2020  Northern District Denies Insurer's Attempt to Avoid Defense Obligation through Extrinsic Evidence Exceptions

The district court found that the insurer failed to establish that the so-called Northfield exception to the "eight corners" rule applied where the underlying pleading sufficiently established that a duty to defend was owed. The court was the first to address the recent Supreme Court of Texas decisions in Richards and Avalos regarding the "policy language" excpetion that the Court had rejected and the "collusive fraud" exception the the Court adopted.

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