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Employing a proximate-cause test, defendant sustained a direct loss under the employee-dishonesty clause in its insurance policy when it was induced by its employee's fraudulent acts to hand over autos in exchange for installment sales contracts signed by noncreditworthy customers and each sale was a separate occurrence; summary judgment should not have been granted since issues of material fact, including defendant's actual losses and if he had the requisite manifest intent, remain for jury determination.
August 23, 2004 at 12:00 AM
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