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4468 The horizontal exhaustion rule requires all primary insurance to be exhausted before an excess insurer must defend an insured, even in a claim for continuing loss, part of which is not within the coverage of the existing primary policy; a self-insured retention that prevents the primary insurer from being liable until the insured has paid a specified amount does not change the obligation of the excess insurer.CitationPADILLA v TRANSPORTATION INS (Horizontal Exhaustion) 150 CA4 984 [See: Community Redevelopment v Aetna 50 CA4 329, T/AT 12/96]
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