(an insurer issued a fertilizer company a $1 million commercial general liability (CGL) policy and a $10 million commercial umbrella liability policy; a customer and his lessor sued the fertilizer company, alleging that its pest control advisor gave them erroneous chemical application advice, leading to the destruction of their grape crop; the insurer partially accepted the fertilizer company’s tender for defense, but only pursuant to the CGL policy; the customer obtained a $9.5 million judgment against the fertilizer company, of which the insurer paid $1 million; the fertilizer company then filed an action against the insurer, alleging that the insurer had improperly denied umbrella policy coverage under a professional services exclusion and an applicator exclusion; in ruling on cross-motions for summary judgment, the court granted summary judgment for the insurer on a reformation claim, but denied summary judgment on breach of contract, declaratory judgment, fraud, and bad faith claims; the court found that a triable issue existed as to whether the damage was caused by an “accident,” which would have triggered coverage under the umbrella policy; it was possible for the fertilizer company to have been liable for the injuries and for the injuries to have arisen out of an accident).