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2786 Self-insured retentions (i.e., deductibles) should not be treated as primary/underlying insurance to which the rule of horizontal exhaustion applies, so an insured under multiple policies should not be required to exhaust its self-insured retentions on all potentially applicable policies before an insurer has a duty to indemnify it for its losses.CitationMONTGOMERY WARD v IMPERIAL (Stacked Deductibles) 81 CA4 356 [See: Cal Pacific v Scottsdale 70 CA4 1187, T/AT 5/99; Montrose v Admiral 10 C4 645, T/AT 8/95; Community Redevelopment v Aetna 50 CA4 329, T/AT 12/96]
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