MEMORANDUM OPINION
LATCHUM, Senior District Judge.
This dispute between New Castle County ("NCC") and U.S. Fire Insurance Company ("U.S. Fire") is the latest spawn of the Tybouts Corner landfill. Three actions ("the underlying lawsuits") have been filed against NCC concerning pollution leaching from the Army Creek and Tybouts Corner landfills. NCC sought a declaratory judgment against twelve insurance companies...
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