New Developments

1) THE NINTH CIRCUIT RULES THAT AN UMBRELLA INSURER HAS A PRIMARY DUTY TO DEFEND DISPARAGEMENT CLAIMS MADE AGAINST A COMPANY'S OFFICERS AND DIRECTORS

2)THE NINTH CIRCUIT COURT OF APPEALS DETERMINED THAT NATIONAL UNION OWED A DUTY TO DEFEND CLIENTS OF ADLESON, HESS & KELLY SUED FOR DISPARAGEMENT