The United States District Court for the District of Columbia, applying Virginia law, denied an insured’s motion for partial judgment on the pleadings in part, finding that an insured person’s receipt of a subpoena does not automatically establish that a governmental agency is investigating both the insured entity and the insured person. Fed. Home Loan Mortg. Corp. v. Twin City Fire Ins. Co., 2024 WL 4722148 (D.D.C. Nov. 8 2024). The court also granted the insured’s motion in part, finding that the excess insurers could not challenge payments made by underlying insurers.