v. Zurich Am. Ins. Co., No. Civ. RDB-12-2876, 2015 WL 1656497, at *2 (D.Md. Apr. 13, 2015) (exclusion where “prior to the effective date of this policy you or any ‘Insured’ had no knowledge of any ‘claim’ or circumstances, involving an act, error, or omission, which may result in a ‘claim’ under this policy” applied only to outstanding claims and to circumstances that insured subjectively believed would result in suit); see also Rivelli v. Twin City Fire Ins. Co., 359 Fed.Appx. 1, 3 (10th Cir.2009) (affirming district court’s holding that exclusion for “any knowledge or information of any act, error, omission, fact or circumstance which may give rise to a claim” necessitated a subjective knowledge standard); James River Ins. Co. v. Hebert Schenk, P.C., 523 F.3d 915, 921 (9th Cir.2008) (<HOLDING>). NCAIG also notes that courts finding
holding that a written statement could not be regarded as an affidavit sufficient in law for any purpose because it was not sworn to by any one or before any officer holding that where law firms insurance application had asked whether any attorneys ajfter inquiry  were aware of any circumstances allegations  or contentions as to any incident which may result in a claim the language  may result denotefd something more than a purely theoretical possibility of a lawsuit holding that juries may not be precluded from considering as a mitigating factor any aspect of a defendants character or record and any of the circumstances of the offense that the defendant proffers as a basis for a sentence less than death holding that juries may not be precluded from considering as a mitigating factor any aspect of a defendants character or record and any of the circumstances of the offense that the defendant proffers emphasis in original recognizing that in certain circumstances inquiry notice may be determined as a matter of law