The United States Bankruptcy Court for the Northern District of Illinois, applying Illinois law, has held that an insured v. insured exclusion in a D&O policy bars coverage for a trustee’s claims against a bankrupt insured condominium association’s former officers and board members where the policy defined “Insured” to include bankruptcy trustees and debtors-in-possession. Avellone v. U.S. Liab. Ins. Co. (In re Ford City Condo. Ass’n), 2023 WL 5624581 (Bankr. N.D. Ill. Aug. 31, 2023).