Filed January 12, 2011
Co. v. Brumfield, 894 N.E.2d 421, 427 (Ill. App. Ct. 2008) (where insurer “was not defending or controlling [insured’s] interests, [insurer] did not have any actual conflicts of interest.”); Illinois Masonic Med. Ctr. v. Turegum Ins. Co., 522 N.E.2d 611, 617 (Ill. App. Ct. 1988) (conflict of interest arose between defending insurer and insured). Evidently Plaintiff recognizes this flaw in his Complaint because he alleges further that AAIC somehow “ratified” St. Paul’s purported failure to disclose a conflict of interest.