Singletary v. Beazley Insurance Co. The parties’ management liability policy expressly excluded coverage for “damages representing amounts allegedly owed” under an express contract. Plaintiffs had to complete a Form SSA-11 in order to become a representative payee, and plaintiffs do not dispute that Form SSA-11 created a contract between plaintiff Family Assistance Management Services (FAMS) and the Social Security Administration, under which FAMS agreed to reimburse the SSA for any misused funds. Therefore, when the SSA demanded repayment of funds that FAMS did not use appropriately as part of its duties as a representative payee, the claim for repayment was under an express written contract.
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