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ZENITH INSURANCE COMPANY v. OCONNOR
Defendant law firm, retained by primary insurer to provide legal services with respect to the defense of certain claims, owed no duty of care to plaintiff reinsurer in absence of express agreement between plaintiff and defendant creating such duty, even though plaintiff had reinsured 100 percent of primary insurer's potential policy liability and had multiple communications with defendant, who was obligated as primary insurer's counsel to keep reinsurer informed of the status of claim adjustment and defense.

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