(January 4, 2024, 1:24 PM EST) -- SEATTLE — An insurer cannot deny coverage to an insured for a professional negligence claim arising out of additional expenses incurred by the insured on a construction project unless the insurer shows that the insured’s failure to tender the claim until after incurring the expenses caused the insurer to suffer actual and substantial prejudice, a Washington federal judge said in denying the insurer’s motion for summary judgment in a breach of contract and bad faith suit filed by the insured....