Don Malecki was an insurance coverage guru. He wrote many treatises regarding insurance coverage. He was respected and a much sought-after insurance coverage expert. Malecki wrote an article in an insurance agent publication, Rough Notes, entitled, Troubled Terminology: “Risks of Direct Physical Loss” Wording Is Currently Read Broadly By Courts.1 He noted that most policyholders do not understand the basic meaning of “risks of direct physical loss”:

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