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On October 1, 2013, the Missouri Court of Appeals, Western District, handed down its decision in Scottsdale Insurance Company v. Addison Insurance Company (WD 75963). This represents the first time a Missouri court has been called upon to resolve a dispute between an excess insurer seeking to recover from a primary insurer the amount contributed from an excess policy in order to resolve a claim where the primary insurer failed to settle the claim within its policy limits.

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