should not be required to pay prenotice attorney’s fees. The policy issued to Sherwood states: 2. Duties in The Event Of Occurrence, Claim Or Suit. d. No insureds will, except at their own cost, voluntarily make a payment, assume any obligation, or incur any expense, other than for first aid, without our consent. (Emphasis added.) Insurance policy provisions forbidding the voluntary incurring of costs are routinely upheld. See, e.g., Lafarge Corp. v. Hartford Casualty Ins. Co., 61 F.3d 389, 400 (5th Cir.1995) (“The terms of the policy are unambiguous and therefore must be enforced as -written.”). Such provisions have been construed to preclude the payment of pre-notice attorneys’ fees by insurers. See Northern Ins. Co. of New York v. Allied Mut. Ins. Co., 955 F.2d 1353, 1360 (9th Cir.) (<HOLDING>), cert. denied, 505 U.S. 1221, 112 S.Ct. 3033,
holding that allied may not be held liable for portion of attorneys fees paid pretender of defense due to policy provision precluding reimbursement for defense costs voluntarily incurred holding attorney fees may be allowed for expenses incurred for default holding insurer vicariously liable for defense counsels negligent defense of a medical malpractice claim holding that attorneys fees are necessaries for the criminal defense of a child holding because washington statute provided for acquitted defendants recovery of attorney fees by motion in criminal action rather than in independent civil action postacquittal attorney fees and costs were incurred in defense of criminal action and therefore subject to reimbursement