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Gregory S. Hirtzel

Greg Hirtzel analyzes important “first manifestation” and “multiple trigger” case from Pennsylvania Supreme Court

Greg Hirtzel recently analyzed an important majority decision handed down last week by the Pennsylvania Supreme Court addressing two coverage issues of significance. The opinion is discussed in greater detail in the attached letter. In sum, the Court held:

  1. Coverage is triggered under the “first manifestation” rule when the damage is reasonably apparent, not when the cause of the damage is recognized as being attributable to the insured’s negligence; and,
  2. The “multiple trigger” theory will not be applied by Pennsylvania courts beyond latent disease cases, like asbestosis or mesothelioma.

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