280 B.R. at 16 ("Whether the proceeds of a D & O liability insurance policy is property of the estate must be analyzed in light of the facts of each case.”). 32 . In re Allied Digital, 306 B.R. at 512; In re SN Liquidation, Inc., 388 B.R. at 584. 33 . See e.g., In re Matter of Vitek, Inc., 51 F.3d at 535 ("[Wjhen a debtor corporation owns a liability policy that exclusively covers its directors and officers, ... the proceeds of that D & O policy are not part of the debtor’s bankruptcy estate.”) (emphasis in original); In re Allied Digital, 306 B.R. at 512 (finding that "when the liability insurance policy only provides direct coverage to the directors and officers the proceeds are not properly of the estate.”). 34 . Id. 35 . Id. 36 . E.g., In re Allied Digital, 306 B.R. at 513 (<HOLDING>); In re Medex, 314 B.R. at 722-723 (holding
holding that the proceeds of a liability insurance policy were not property of the estate holding that because no claims had been filed against the debtor existence of entity coverage did not make proceeds property of the estate holding that where the policy names only the directors or officers as insured the proceeds are not property of the estate holding that because proceeds of a letter of credit were not secured by estate collateral the proceeds were not property of the estate holding that the policy proceeds were not property of the estate because the trustee has made no credible showing that the direct coverage of allied digital under clause bi for securities claims has any continuing vitality