CHRIS KLEVELAND v. CHICAGO TITLE INSURANCE COMPANY
An arbitration clause in a title insurance policy is not enforceable where preliminary title report did not mention arbitration and referred to a policy that was different than that actually issued by insurer. Where preliminary report referring to an ALTA policy did not indicate policy would include arbitration clause, but title insurance company later issued a different policy that did contain an arbitration clause, latter policy's arbitration clause was not incorporated by reference into preliminary report and was not binding on insured.
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