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Cadre v. Proassurance Cas. Co.

New Jersey Appellate Division

June 9, 2021

Forget your clients, lawyers. This opinion is important for you. An attorney sued her professional liability insurer and broker after the insurer declined to provide coverage when a paralegal misappropriated about $800,000 in client funds. Rule 1:21-1B requires coverage for attorneys for all damages from any claim by a client, but the insurance policy procured by the plaintiff carved out misappropriation as an area where it would not provide coverage. Plaintiff argued that the courts should mandate coverage to conform with the minimum requirements. The Appellate Division refused to do so and affirmed the Law Division’s order granting summary judgment in favor of the insurer.

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