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Draft a Memo
Write a paper, addressing the following scenario. Please write in full paragraphs and sentences, using details and analysis to support your answers.
Fact Scenario
Mr. and Mrs. Turner own an apartment building on East 158th Street in Queens, NY. They live in one of the apartments and rent out the other three units in the building.
Mr. and Mrs. Cavanaugh rent one of the apartments. The Cavanaughs have a 4-year-old son named Jason. Jason had not been feeling well, so the Cavanaughs brought him to his pediatrician.
After a battery of tests, it was determined that he had high levels of lead in his system. Testing of the paint in the Cavanaughs’ apartment confirmed that the paint used in the apartment was old and included high levels of lead. The Turners had taken out a commercial general liability coverage insurance policy (“the policy”) with the Youngston Insurance Company. The policy was taken on their property on East 158th Street. The policy, which was purchased prior to the Cavanaughs moving into the apartment, is still in effect. The policy has a general pollution exclusion but does not specifically list lead paint as pollution. The language of the exclusion discusses injuries caused by “discharge, dispersal, release, or escape of pollutants.”

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