Plaintiffs theory any losses that occur subsequent in time to the excluded workmanship are restored simply because of the passage of time. Such a theory is contrary to basic Virginia principles of contract interpretation. See TM Delmarva Power, LLC v. NCP of Virginia, LLC, 263 Va. 116, 557 S.E.2d 199, 201 (2002) (“no word or clause in a contract will be treated as meaningless if a reasonable meaning can be given to it, and parties are presumed not to have included needless words in the contract”) (citing D.C. McClain, Inc. v. Arlington County, 249 Va. 131, 452 S.E.2d 659, 662 (1995)). Moreover, the courts in both Holland and Performing Arts specifically addressed, and declined to follow, Plaintiffs line of argument. Holland v. Breaux, 2005 WL 3542899, at *6 (E.D.La. Nov. 22, 2005) (<HOLDING>); see also Performing Arts Cmty. Improvement
holding that a loss of consortium is separate and independent from the primary action holding that proof of loss is not evidence of extent of loss and insured is not precluded from showing his damages were greater than shown in proof of loss holding that insured must be able to separate the cause of the collapse from excluded conduct in order to trigger the ensuing loss clause holding in a case involving a multiplevehicle policy that a new offer of uninsured motorist coverage was not required for the addition of a new vehicle which was comparable to the renewal or supplementation of an existing policy events that did not trigger the statutory requirement of a new offer the courts holding was based in part upon the principle that an insurance contract is personal to the insured because it insures the risk of loss to the insured and does not attach to specific vehicles recognizing that loss of consortium is a right of action separate from that of the spouse