Much has been said (and litigated) about one vs. multiple occurrences in commercial lines, particularly with regard to 9/11 and the World Trade Center. However, this issue may arise in personal lines as well, as illustrated by two examples in this article. First, is damage cause by animals over time a single occurrence or possibly thousands of occurrences? Second, are Hurricanes Charley and Frances (and perhaps Ivan) one or separate occurrences?
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