Applying Texas law, a federal district court in Texas has held that, although a client’s claim against an insured law firm regarding a fee dispute did not implicate “professional legal services,” it arose out of the performance of such services, and thus it triggers the insurer’s duty to defend. Shamoun & Norman, LLP v. Ironshore Indem., Inc., 2014 WL 5460475 (N.D. Tex. Oct. 28, 2014).
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