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The US Court of Appeals for the Tenth Circuit found that a plaintiff’s complaint failed to trigger a duty to defend the driver of a car in the underlying suit because the complaint failed to state any facts that could have plausibly given rise to a claim covered by the relevant insurance policy, and that without extrinsic evidence, it could not be concluded from the relevant documents, the complaint and the policy, that the driver was an insured under the policy. The case is Chavez v. Ariz. Auto. Ins. Co., No. 18-1473, 2020 U.S. App. LEXIS 1603 (10th Cir. Jan. 17, 2020).

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