(March 13, 2020, 8:33 AM EDT) -- PHOENIX — The Ninth Circuit U.S. Court of Appeals on March 9 held that a lower federal court properly determined that breach of fiduciary duty and negligent misrepresentation claims against an insured failed to allege “property damage” under an insurance policy or an occurrence within the policy period (757BD, LLC v. National Union Fire Insurance Company of Pittsburgh, PA, No. 18-16760, 9th Cir., 2020 U.S. App. LEXIS 7502)....