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It was decided on appeal in October of 1981, when the Court of Appeals for the District of Columbia Circuit not only overturned the decision by the lower court to adopt a prorata exposure theory but ruled that Keene could utilize the limits of any single liability policy, and carried the exposure theory a step further by embracing what came to be known as the triple-trigger approach

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The reports must be sent to each state's treasury or designated collector of taxes and include such data as "the name and address of the person to whom the shipment was made, the brand, and the quantity thereof."[43] In December 1951 at the Indiana-Michigan border, authorities stopped a semi-trailer that was escorted by a car carrying a driver and three armed men