The Impact of COVID-19 on the Insurance Coverage Industry - WEBINAR
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WEBINAR The Impact of COVID-19 on the Insurance Coverage Industry Tuesday, April 6, 2021 Paul White Partner – Los Angeles, CA 213.330.8818 paul.white@wilsonelser.com
4/6/2021
Insurance Coverage Master Class
The Fallout of COVID-19
& The Emerging Risks on
the Insurance Industry
April 6, 2021
Today’s Speaker Insurance Coverage Master Class
Paul S. White
Wilson Elser
555 South Flower Street
29th Floor
Los Angeles, California 90071
213.330.8818
paul.white@wilsonelser.com
COVID-19 Insurance Coverage Master Class
Evolution of the Pandemic:
Impact on Insurance
1
4/6/2021
The Cost: How It’s Being Transferred to Carriers Insurance Coverage Master Class
Insurance Coverage Implications:
Three Key Facts
1. Exponential Growth
2. It’s Not the Flu
3. Social Distancing is the
Only Proven Effective Measure
Mounk, Yascha, The Atlantic, “Cancel Everything” (March 10, 2020
Exponential Growth Insurance Coverage Master Class
It’s Not the Flu Insurance Coverage Master Class
Flu affects 9.3 to 45 million in USA
140,000 to 800,000 U.S. hospitalizations
12,000 to 61,000 deaths in U.S.
37,000 deaths in USA in 2019
Globally:
600 million to 1.2 billion infected
500,000 to 1 million deaths
280 million immunizations
2
4/6/2021
Social Distancing is the Only Proven Effective Measure
John Hopkins University, Coronavirus Resource Center Insurance Coverage Master Class
Social Distancing is the Only Proven Effective Measure
John Hopkins University, Coronavirus Resource Center Insurance Coverage Master Class
China: Total Cases: 101,861
Total Deaths: 4,841
Variants Raise Risk of Repeat Cycle Insurance Coverage Master Class
3
4/6/2021
Variants Raise Risk of Repeat Cycle Insurance Coverage Master Class
Pandemics: Policy Wording & Litigation Insurance Coverage Master Class
• COMMERCIAL PROPERTY
• Commercial property
• Contingent business interruption
• Specialized business interruption
• LIABILITY INSURANCE
• General liability
• Errors & omissions
• Directors & officers
• EVENT CANCELLATION
• EMPLOYER LIABILITY / WORKERS
COMPENSATION
Commercial Property Coverage Insurance Coverage Master Class
The Dollars at Issue
• Organization for Economic Cooperation
and Development
• Projects $1.5 trillion lost to the disease.
• American Property Casualty Insurance
Association
• Estimates losses for businesses with 100 or
fewer employees could cost between $220
billion and $383 billion per month.
• Insurance Journal
• COVID-19 pandemic could result in net losses
from $3.2 trillion and up to $4.8 trillion in
U.S. real gross domestic product over the
course of two years (citing USC study).
4
4/6/2021
Business Interruption Litigation
Over 1,500 Declaratory Relief Actions in USA
Insurance Coverage Master Class
Direct Physical Loss: Physical Damage Insurance Coverage Master Class
New York: Social Life Magazine, Inc. v. Sentinel Ins. Co.
“I feel bad for your client. I feel bad for every small business that is having
difficulties during this period of time. But New York law is clear that this kind of
business interruption needs some damage to the property to prohibit you from
going. You get an A for effort, you get a gold star for creativity, but this is just not
what's covered under these insurance policies.” (May 14, 2020, hearing)
Michigan: Gavrilides Mgmt. Co., et al. v. Michigan Insurance Co., Case No. 20-258-CB-C30
Court concluded policy was clear and only covered direct physical loss of or
damage to property, which has to be something that alters the physical integrity
of the property—and held there was none.
Direct Physical Loss: Physical Damage Insurance Coverage Master Class
“The word 'physical' is defined as 'of or relating to material
nature, or to the phenomenal universe perceived by the
senses; pertaining to or connected with matter; material;
opposed to psychical, mental, spiritual.” Patel v. Am. Econ.
Ins. Co., No. 12-CV-04719-WHO, 2014 WL 1862211, at *5
(N.D. Cal. May 8, 2014) (court held feng shui consultant
fees were not covered business income expense and
defined “direct physical loss.”
Air may qualify as a physical thing: “Certainly air is not
mental or emotional, nor is it theoretical.” Oregon
Shakespeare Festival Ass’n. v. Great Am. Ins. Co., No. 1:15-
CV-01932-CL, 2016 WL 3267247 at *9 (D. Or. June 7,
2016), vacated, No. 1:15-CV-01932-CL, 2017 WL 1034203
(D. Or. Mar. 6, 2017) (Court held structural damage to
theater, which closed due to ambient wildfire smoke and
poor air quality, was not required for there to be a physical
loss since theater had to be cleaned and filters replaced).
54/6/2021
Direct Physical Loss: Physical Damage Insurance Coverage Master Class
Policyholder counsel have repeatedly
asserted that the unpublished decision
of Gregory Packaging, Inc. v. Travelers
Property and Casualty Co. of America,
No. 12-CV-04418, 2014 U.S. Dist. LEXIS
165232 (D.N.J. Nov. 25, 2014) supports
an argument that the presence of the
virus in a building will satisfy the direct
physical loss requirement. Notably,
however, in Gregory Packaging, the
presence of ammonia in the building
had made the building uninhabitable.
Direct Physical Loss:
Actual or Feared Physical Damage? Insurance Coverage Master Class
Business closures / lockdowns to
prevent transmission
Foster Farms: reasonable probability
of actual contamination may qualify
Source Tech: To consider border
closure due to concerns re mad cow
disease a “direct physical loss” would
render the word “physical”
meaningless
Direct Physical Loss: Insurance Coverage Master Class
Can the Property be Cleaned or Remediated?
Insurers rely on case law to
support that property that may be
cleaned or remediated has not
suffered direct physical loss.
64/6/2021
Direct Physical Loss: Physical Damage Insurance Coverage Master Class
Missouri: Studio 417, Inc., et al. v. The Cincinnati Insurance Company, Case No. 20-cv-03127-SRB
(W.D. Mo. August 12, 2020)
• Judge Bough first held that plaintiffs adequately alleged a direct “physical loss” under the policies
because relying on the plain meaning of physical loss, plaintiffs alleged a causal relationship
between COVID-19 and their alleged losses. Judge Bough agreed with plaintiffs’ arguments that
the complaint alleged COVID-19 “is a physical substance,” that it “live[s] on” and is “active on inert
physical surfaces,” is also “emitted into the air,” and had attached to and damaged plaintiff’s
property in a manner that left it unsafe. Based on these allegations, the Court held that plaintiffs
plausibly alleged a “direct physical loss” based on “the plain and ordinary meaning of the phrase”
sufficient to withstand the insurer’s Rule 12(b)(6) motion to dismiss.
• Motion to Dismiss—not a ruling on the merits.
Direct Physical Loss: Physical Damage Insurance Coverage Master Class
North State Deli et. al v. Cincinnati Insurance Co., Case No. 20-CVS-02569
• Court granted the policyholders’ motion for partial summary judgment
• Judge stated that “the use of the conjunction ‘or’ means - at the very
least - that a reasonable insured could understand the terms ‘physical
loss’ and ‘physical damage’ to have distinct and separate meanings.”
Direct Physical Loss: Physical Damage Insurance Coverage Master Class
Courts may vary within a single jurisdiction. In Virginia:
Elegant Massage (State Court): “Based on the case law, the Court finds that it is
plausible that a fortuitous “direct physical loss” could mean that the property is
uninhabitable, inaccessible, or dangerous to use because of intangible, or non-
structural, sources.”
The court recognized other decisions finding that “direct physical loss” requires
structural damage or distinct and demonstrable physical alteration, but concluded
where multiple interpretations may exist, it should apply the interpretation most
favorable to the insured.
Skillets, LLC: “Sillets did not suffer a direct physical loss as a result of COVID-19 or the
closure orders, and its business losses incurred as a result of these events are
therefore not covered by the Policy.” (Note applying Florida law.)
74/6/2021
Direct Physical Loss: Civil Authority Insurance Coverage Master Class
• Damage arose from civil authority action or order
• Impair or prohibit access
• Direct Physical Loss to Property Other Than Described Premises
• Contagious or infectious disease (hospitality and health care)
• Waiting Period (72 hours)
• Restrictions on time / policy sublimit
• Restrictions on geography (one-mile radius)
Direct Physical Loss: Physical Damage Insurance Coverage Master Class
Covid Coverage Litigation Tracker, cclt.law.upenn.edu/judicial-rulings/ April 4, 2021
Direct Physical Loss: Physical Damage Insurance Coverage Master Class
Dismissal / Motion Denied Virus Exclusion Judgment for
Judgment for Insured
Insurer
AL, AZ, CA, CT, DC, AL, CA, FL, IL, MO, AL, AZ, CA, CT, FL, IL, NC, OH, OK, PA,
FL, GA, IA, IL, IN, NC, NJ, NV, NY, OH, GA, IA, IL, IN, KY, VA, WA
KS, KY, LA, MA, MI, OK, PA, SC (insured MA, MI, MN, MO,
MN, MO, MS, NC, msj), TN, TX, VA, MS, NC, NJ, NM,
NJ, NM, NV, NY, OH, WA, WI, WV NV, NY, OK, PA, TN,
OK, PA, TX, VA, WA, TX, VA, WA, WV
WI, WV
31 STATES 19 STATES 27 STATES 7 STATES
84/6/2021
Commercial Property: Exclusions Insurance Coverage Master Class
• Virus
• Pollutants or Contaminants
• Micro-organisms or other substances that threaten human
health and life
• Acts or decisions of government bodies
• Arising from enforcement or compliance with any law
• “Property damage” arising from exposure to land, water, air
Commercial Property: Virus Exclusion Insurance Coverage Master Class
• ISO form CP 01 40 07 06 provides in pertinent part:
• EXCLUSION OF LOSS DUE TO VIRUS OR BACTERIA
• The exclusion set forth in Paragraph B. applies to all coverage under all forms
and endorsements that comprise this Coverage Part or Policy, including but not
limited to forms or endorsements that cover property damage to buildings or
personal property and forms or endorsements that cover business income,
extra expense or action of civil authority.
• We will not pay for loss or damage caused by or resulting from any virus,
bacterium or other microorganism that induces or is capable of inducing
physical distress, illness or disease. … (Emphasis added)
Commercial Property: Virus Exclusion Insurance Coverage Master Class
• When ISO submitted the exclusion to state regulators in July 2006, its circular LI-CF-2006-175
expressly identified SARS—the virus from which COVID-19 mutated—as a type of virus that the
exclusion is designed to address. The ISO circular stated: [E]xamples of viral and bacterial
contaminants are rotavirus, SARS, influenza (such as avian flu), legionella and anthrax. The universe
of disease-causing organisms is always in evolution.”
• “While property policies have not been a source of recovery for losses involving contamination by
disease-causing agents, the specter of pandemic or hitherto unorthodox transmission of infectious
material raises the concern that insurers employing such policies may face claims in which there are
efforts to expand coverage and to create sources of recovery for such losses, contrary to policy
intent.
In light of these concerns, we are presenting an exclusion relating to contamination by disease-
causing viruses or bacteria or other disease-causing microorganisms.” Id
94/6/2021
Virus Exclusion Insurance Coverage Master Class
Does the government order cause the shutdown?
Henderson Road Rest. Sys., Inc. v. Zurich Am. Ins. Co. (ND Ohio):
The virus exclusion did not apply to bar coverage because the COVID-19 virus
itself did not cause the losses at issue, but rather the government shutdown
orders did.
Franklin EWC v. The Hartford Financial Services Group Inc. et al., Case No. 3:20-cv-
04434:
Federal California court upheld the virus exclusion in a COVID-19 business
interruption case, calling the plaintiff’s argument that the exclusion should not
apply because stay-at-home orders were the actual cause of loss “nonsense.”
Commercial Property: Pollution Exclusion Insurance Coverage Master Class
• Many Policies Exclude Pollutants and Contaminants
• Many Policies Define Pollutant or Contaminant to Include Virus
• Pollution Exclusions (Pollutant not defined): Courts are split--
• Virus can be a pollutant. See First Specialty Insurance Corp. v. GRS Management Associates,
Inc., No. 08-81356, 2009 WL 2524613, at **3, 5 (S.D. Fla. Aug. 17, 2009).
• Westport Insurance Corp. v. VN Hotel Group, LLC, 761 F. Supp. 2d 1337, 1343-44 (M.D. Fla.
2010) (Court determined legionella bacteria are not pollutants; pollution exclusion did not
apply).
• Johnson v. Clarendon National Insurance Co., No. G039659, 2009 WL 252619, at **2, 13
(Cal. Ct. App. Feb. 4, 2009) (pollution exclusion did not apply to mold and likely would not
apply to viral infections; court interpreted in favor of coverage).
Acts or Decisions of Government Bodies Insurance Coverage Master Class
Florexpo LLC v. Travelers Property Casualty Co., Case No. 20-DV-
1024 JLS (DEB)
We will not pay for any loss or damage caused by or resulting from . . .
Acts or decisions, including failure to act or decide, of any person, group,
organization or government body . . . .
104/6/2021
Acts or Decisions of Government Bodies Insurance Coverage Master Class
Florexpo LLC v. Travelers Property Casualty Co., Case No. 20-DV-
1024 JLS (DEB)
“First, the governmental action was the direct cause of the loss for which
Plaintiffs seek relief in the Coverage Claim, bringing the claim within the Acts or
Decisions Exclusion. Second, the Court refuses to read a negligence limitation
into the Exclusion, where such language does not exist and where courts
interpreting similar exclusions have not limited the clause to only negligent acts.”
Exclusion: Micro Organisms Or Other Substances
Insurance Coverage Master Class
That Threaten Human Health And Life
Henderson Road Rest. Sys., Inc. v. Zurich Am. Ins. Co. (ND Ohio)
• Plaintiffs argued virus must be present on premises.
• Insurance filing with Ohio DOI where carriers “explained that despite the broad language of the
exclusion, they were seeking to avoid coverage for ‘viral and bacterial contamination’ of
properties.”
• Parties had stipulated that plaintiffs’ closures were not based on presence of virus at their
properties.
• Court delayed discovery on damages pending appeal based on “substantial ground for difference of
opinion” on policy interpretation. (Similar question certified to Ohio Supreme Court same day in
Neuro-Commc’n Serv., Inc. v. The Cincinatti Ins. Co.
Business Interruption Litigation
Over 1,500 Declaratory Relief Actions in USA
Insurance Coverage Master Class
114/6/2021
Disease Clause Extension (EU) Insurance Coverage Master Class
The insurer shall pay compensation if the competent authority
closes the insured business in whole or in part to prevent the
spread of notifiable diseases or pathogens on the basis of the
law on the prevention and control of infectious diseases or
pathogens.
Disease Clause Extension (EU) Insurance Coverage Master Class
• France: Manigold v. AXA
• A Paris court ruled that insurer AXA must pay a restaurant owner two months’ worth of coronavirus-related revenue losses.
• Court advised policy did not include “direct physical loss” requirement
• French insurers estimate $21.8 billion per month
• AXA as reportedly agreed to pay over 200 COVID-19 related claims
• Germany: Government and group of insurers reached an agreement whereby government pays 70 percent of business
interruption losses for policyholders in hospitality industry and insurers pay for half of business interruption losses not covered by
the government
• United Kingdom: FCA v. Hiscox et al.
• Financial Conduct Authority selected eight insurers to participate in High Court test case.
• Eight insurers—will impact 700 policy types, 60 insurers, 370,000 policyholders.
• Selected representative policy language and wordings in order to provide guidance for many other business interruption policy
forms
• Direct Physical Loss not an issue (paragraph 80)
• Disease clause cover extensions (or hybrids). Court determined COVID-19 in UK is an occurrence
Specialized Business Interruption Insurance Coverage Master Class
• Hospitality and Health Care
• Communicable and Infectious
Diseases
• Pandemic Specific
• Coverage
• Exclusions
124/6/2021
Legislative Intervention Insurance Coverage Master Class
• Retroactive imposition of contractual obligations
• Absence of Underwriting or Premium
• United States Constitution:
• Contracts/ Impairments Clause: “[n]o state shall … pass
any … Law impairing the Obligation of Contracts.” (U.S.
Constitution, Art. I, § 10, emphasis added.)
• Takings Clause
• Due Process Clause
• Pandemic Risk Insurance Act
Liability Exposures Insurance Coverage Master Class
Adjusting Claims in the Virtual World
• General Liability: Bodily Injury and
Property Damage
• E&O: Health Care
• E&O: Agent Broker
• D&O: Securities
• Waivers and Immunity
Liability Exposures: GL / E&O / D&O Insurance Coverage Master Class
Adjusting Claims in the Virtual World
• Banking / Financial Services • Insurance
• Challenge vs. Foreign Sovereigns or • Intellectual Property
non-government organizations • Labor & Employment
• Civil Rights • Miscellaneous Tort
• Consumer cases
• Libel, Slander, Defamation
• Contract Disputes
• Other
• Education
• Wrongful Death / Personal Injury
• General court administrative orders (other than employment / consumer /
re COVID-19
healthcare)
• Habeas / Confinement / Prisoner
• Health / Medical • Real Property
• Securities Litigation
134/6/2021
Fear of Disease Insurance Coverage Master Class
Does Not Support Emotional Distress
Weisberger v. Princess Cruise Lines, Case No. 2:20-cv-
02267-RGK-SK (July 14, 2020)
• Passenger-plaintiffs could not recovery for NIED
based solely on their proximity and fear of
contracting the disease from others with COVID-
19.
• The Court noted that if it were to adopt the
plaintiffs’ position, it would run afoul of a US
Supreme Court decision leading “to a flood of
trivial suits, and open the door to unlimited and
unpredictable liability.”
• It also expressed that the risk of exposing
individuals to COVID-19 is not unique to cruise
ships-“quite the contrary, in fact, as restaurants,
bars, churches, factories, nursing homes, prisons, CNBC March 28, 2020, “CDC says coronavirus RNA found in
and other establishments across the country
Princess Cruise ship cabins up to 17 days after passengers left”
CNBC.com last visited 3/7/2021)
continue to report COVID-19 cases,” and as such
creating a “cruise-ship exception” was not
warranted.
General Liability Insurance Insurance Coverage Master Class
• Bodily Injury
• Property Damage
• Occurrence = Accident
• Damages
• Allegations of gross negligence
• Allegations of intentionally
disregarding warnings
• Allegations of failure to comply with
civil authority directives
• Statutory Violations are not
accidents
• Requests for Injunctive Relief
General Liability Insurance Insurance Coverage Master Class
McDonald’s Corp., et al. v. Austin
Mutual Insurance Company, Case:
1:20-cv-05057 (ND IL Feb. 22, 2021)
• Claim for injunctive relief
• “Damages because of bodily
injury”
• Court declined to address
employment and workers
compensation exclusions
CNBC March 28, 2020, “CDC says coronavirus RNA found in
Princess Cruise ship cabins up to 17 days after passengers left”
CNBC.com last visited 3/7/2021)
144/6/2021
Insurance Coverage Master Class
Other Insurance Product Lines Impacted by COVID-19
Errors & Omissions Insurance
Health Care
Insurance Coverage Master Class
E&O coverage for medical professionals and managed care
operations
Coverage: Insuring clauses generally provide coverage for
bodily injury to a patient arising out of acts, errors, or
omissions in providing or failing to provide medical care or
managed care.
Exclusions: Policies generally exclude coverage for bodily injury
to employees during the course of their employment (i.e., an
employee being exposed to an infectious or contagious
disease).
Errors & Omissions Insurance
Insurance Agent & Broker
Insurance Coverage Master Class
Standard of Care
• Broker only required to obtain requested coverage
• “Special Circumstances Rule”
Broker makes representations re nature, extent, or scope of coverage
being offered or provided
Client requests specific coverage
Broker assumes additional duty by express agreement or by “holding
himself out” as having expertise in a given field.
• Professional Standard
Duty to advise
154/6/2021
Errors & Omissions Insurance Insurance Coverage Master Class
Insurance Agent & Broker
Casa Colina, Inc. v. Hartford Fire Ins. Co, HUB, 2020 U.S. Dist LEXIS 236698
(Dec. 23, 2020)
(1) a broker warranting that Plaintiffs would receive “full and adequate
insurance” is a generalized statement that is insufficient to amount to a
misrepresentation that would trigger a heightened duty;
(2) the broker did not have an affirmative duty to warn of potential
coverage gaps or exclusions absent a specific inquiry; and
(3) the broker was not “holding out” as having expertise when it discussed
business interruption coverage on the broker’s website.
Directors & Officers Insurance Insurance Coverage Master Class
COVID-19 has roiled stock markets worldwide.
Claims as to whether:
• company was sufficiently prepared;
• whether appropriate steps taken in response;
• Responsibility for failed mergers
• Exclusions for Bodily Injury and Property Damage
• Absolute bodily injury exclusion: “based directly or
indirectly arising out of, or relating to actual or
alleged bodily injury.” Intended to preclude
coverage for any claim, even economic loss, arising
out of or related to bodily injury. Such exclusions
are being challenged in courts.
Event Cancellation &
Contingency Nonappearance Insurance
Insurance Coverage Master Class
164/6/2021
Event Cancellation &
Contingency Nonappearance Insurance
Insurance Coverage Master Class
Communicable Diseases: “Most event cancellation insurance policies do not cover losses from communicable diseases like
the coronavirus, except where such coverage is sold as an add-on. Moreover, that coverage is often only triggered when the
government stops the event from going ahead, rather than when the organizer decides to cancel or attendees drop out.”
Law360UK, “Swiss Re Faces $250M Loss if Olympics Canceled,” (March 20,2020)
Generally: communicable or infectious diseases are not included as specified perils in standard event cancellation policies.
See, e.g., “Coronavirus and Event Cancellation Insurance,” Washington State Office of the Insurance Commissioner,”
https://www.insurance.wa.gov/coronavirus-and-event-cancellation-insurance (last visited April 4, 2020)
Insurance Coverage Master Class
Risks & Liabilities Facing Employers & Businesses
Covid-Standards
Workers’ Compensation Claims
174/6/2021
Remote Workers and Resulting Risks
Wage & Hour Issues
Performance
Management
Privacy & Cyber
Workers’ Compensation
Can Employers Require Employees
To Be Vaccinated?
Vaccines, Generally
Employer Mandates
Risks With Mandates
Mandates For The Public
Liability Traps
Waivers for Businesses vs. Waivers for Employees
184/6/2021
Thank You!
Paul S. White
Wilson Elser
555 South Flower Street
29th Floor
Los Angeles, California 90071
213.330.8818
paul.white@wilsonelser.com
Dean A. Rocco
Wilson Elser
213.330.8922
dean.rocco@wilsonelser.com
19Paul S. White
Partner
Contact
Los Angeles
p. 213.330.8818
f. 213.443.5101
paul.white@wilsonelser.com
Paul White focuses his practice on complex insurance coverage and bad faith litigation and
Services
represents defendants in commercial litigation. Paul's insurance coverage practice includes
Appellate advising and representing insurers in bad faith litigation and insurance policy disputes,
Germany including rst-party property policies, general liability coverage, errors and omissions
insurance, and media liability insurance. He also advises and represents insurers in
Insurer Litigation:
subrogation actions on property losses. In addition, Paul has litigated and arbitrated disputes
Coverage/Extra-Contractual
throughout the United States involving domestic and foreign insurance agents and brokers in
Insurance & Reinsurance all lines of coverage. He has broad experience in the business practices of all types of
Coverage insurance intermediaries, including brokers at every level in the broking process, from
producers to managing general agents to London Market brokers.
Professional Liability & Services
In his litigation practice, Paul focuses on commercial business litigation, including
professional liability actions brought against insurance agents and brokers. In addition to his
Admissions insurance practice, Paul advises entertainment and technology companies on the
Bars management of intellectual property risks.
California
Paul regularly speaks and publishes for groups such as DRI, the Professional Liability
Courts Underwriting Society (PLUS), Property & Liability Resource Bureau/Liability Insurance
Supreme Court of the United States Research Bureau (PLRB/LIRB), the Federation of Defense and Corporate Counsel, and the
U.S. Court of Appeals, Ninth Circuit National Business Institute on insurance coverage issues, including, among others,
U.S. Court of Appeals, Tenth Circuit intellectual property, bad faith, professional liability, employment, environmental and
U.S. District Court, Northern District of
construction defects. In 2016, Paul received the Outstanding Presenter award from PLRB.
California
U.S. District Court, Central District of
California
U.S. District Court, Eastern District of
California
U.S. District Court, Southern District of
California
Memberships & A liations
DRI: The Voice of the Defense Bar; chair,
Insurance Coverage & Claims Institute,
2016; former chair, Insurance Committee;
former chair, Publications Committee;
former editor, “Covered Events”
The Federation of Defense & Corporate
Counsel (FDCC), Extra-Contractual Liability
Section, vice chair
Awards & DistinctionsSelected for inclusion in Southern California Super Lawyers®, 2017- 2020 Education University of Utah S.J. Quinney College of Law, J.D., 1989 Brigham Young University, B.A., 1985 Certi cations/Licenses
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