Excess “Follow Form” Policy Does Not Cover Underinsured Motorist Claim Covered By Underlying Policy

Uninsured motorist (“UM”) and underinsured motorist (“UIM”) coverages “are strictly ‘first party’ coverages because the insurer’s duty is to compensate its own insured for his or her losses, rather than to indemnify against liability claims from others,” according to the Court of Appeal in Haering v. Topa Insurance Company, 244 Cal.App.4th 725 (2016)(italics in original).

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