as a result of periods of time when it was uninsured or self-insured.” Steuber, supra, at *60. The leading case for that proposition is Insurance Co. of North America v. Forty-Eight Insulations, Inc., 633 F.2d 1212 (6th Cir.1980), clarified, 657 F.2d 814 (6th Cir.), cert. denied, 454 U.S. 1109, 102 S.Ct. 686, 70 L.Ed.2d 650 (1981). Courts taking the same allocation approach as Forty-Eight Insulations include Gulf Chemical & Metallurgical Corp. v. Associated Metals & Minerals Corp., 1 F.3d 365, 372 (5th Cir.1993) (apportioning cost of policyholder’s defense among insurers on risk; policyholder must bear its share of defense costs determined by fraction of time it lacked coverage) (applying Texas law); Fireman’s Fund Insurance Cos. v. Ex-Cell-O Corp., 685 F.Supp. 621, 626 (E.D.Mich.1987) (<HOLDING>); and Northern States Power, supra, 523 N.W.2d
holding insurer on risk during period of alleged exposure liable for policyholders defense in proportion that period on risk bears to total period of alleged exposure policyholder must bear prorata share of costs for uninsured periods holding that an eighth amendment plaintiff did not have to prove that he was actually injured by exposure to raw sewage only that such exposure posed a serious health risk holding that the charge was timely when filed within the statute of limitations period even though served after the period holding that insurance coverage in the context of asbestosrelated diseases is triggered by exposure exposure in residence and manifestation holding several defendant insurers liable where policyholders allegedly exposed the sites to pollutants during policy periods