The Cause Test
The cause test was also applied in Owens-Illinois v. United Insurance Company, 264 N.J. Super. 460, 625 A. 2d 1 (1993). The court found that multiple underlying asbestos-related injury claims constituted a single occurrence. As a result of the single-occurrence holding, the insured avoided paying a separate, per-occurrence deductible for each underlying claim. If it had been required to pay a deductible for every claim the insurance would never have come into effect.
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