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E&O Insurer Has No Duty to Defend Dispute Limited to Recovery of Fees

Sep 28, 2021, 16:21 PM by Wiley Rein LLP

Published September 28, 2021 • JD Supra


Applying Florida Law, the United States District Court for the Middle District of Florida has held that a professional liability insurer had no duty to defend an action that exclusively sought the return of fees charged by the insured where such amounts fell within an exception to the definition of “damages.”  RLI Ins. Co. v. Baywalk Title Inc., 2021 WL 4437163 (M.D. Fla. Sept. 27, 2021).