The Washington Court of Appeals ruled this week that a limited liability company’s directors and officers (D&O) insurance policy did not cover a claim by a lender against the LLC’s manager on the manager’s guaranty of the LLC’s debt. Sauter v. Houston Cas. Co., No. 66809-9-I, 2012 WL 1699447 (Wash. Ct. App. May 14, 2012). … Continue Reading