I have a PA challenging me on a DP3 policy (no contents coverage; the insured's reside at the risk).  This is a fire loss.  

The first issue is because there is no Coverage C available and in order to complete the repairs, the contents need to be moved. I was thinking we owe content manipulation to remove the personal property to access repairs.  Do we owe for storage and return?  Or just to return the contents? Unfortunately there is no space to store the contents at the house- the garage was burned to the ground.

The second issue is the PA hired his contractor to place a temporary fence around the property.  Apparently there was an attempted break in and now the insured wants all the locked windows and doors boarded up.  I advised him that damage caused by forced entry is covered if he wanted to pursue a 2nd claim.  I don't feel we owe to board up closed/locked windows and doors; if they were broken or open, then I could see it.  The PA is claiming we are not doing our job to protect the property from further damage.

California Subscriber

Removal of the contents is required to repair the building so removal is covered; the property can't simply be left on the street and since the carrier owes to move it to make repairs, the carrier should pay for storage as well. The storage is the result of the loss to the dwelling, coverage A, and is not related to any loss to the property that would be covered under coverage C.

As far as boarding up the windows and doors, the policy pays for reasonable necessary measures to prevent further damage. There was no damage caused by theft; there was only an attempted theft. The loss was caused by fire. Boarding the doors and windows is not a reasonable measure to protect the property from further loss; this is not covered. In the duties after a loss section the insured is required to protect the property with reasonable and necessary repairs and keep receipts; however there is no promise of coverage for all the insured's actions, especially if they are unreasonably cautious.

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