the proper interpretation of this policy is that a loss is a cover cost of loss and that mr foley is entitled to the additional recovery that he seeks i'm sure your honour's are well aware of the fact in the interest of time i can briefly restate them in the procedural history or i can go directly to the argument we do have a precedent in illinois though well established principles a policy interpretation station as set forth by illinois courts these principles include an insurance policy is construed giving effect to every provision because it's assumed that every provision was intended to serve a purpose if the words in the policy are unimpeded was when given their plain and ordinary meaning they must be applied as rid of function of the court up the additional coverage for sewer back up the additional coverage for debris removal and the additional coverage for construction for the starting point is the coverage right which is found in the very st sentence of section eight of the  yes but then the according to the policy the overflow dams the limited the twenty five thousand dollars for food under the overflow additional coverage written and that it if you look at the additional coverage language the additional coverage for sewer backup and overflow says it's twenty five thousand dollars for this additional coverage now mind temporary things you got additional coverage and this is all the fight every single one of these is this additional coverage it doesn't say and no other coverage is apply it to court if the zirp wanted us to interpret it that way it could have sat this is it and no other additional coverage is the pot it's not how this policy is written and that's not how if you look at the debris removal coverage of the instruction forms operatives again there they there and say exclude it but it's written in a way for a reason the exclusion language is then immediately followed in the same provision by an exception that refers to this additional coverage and it's very very got this is excluded except it's one it's covered and it's over so there's nothing left to be excluded that not under no circumstances is sewer backup excluded it is completely covered specific it's assumed that the insured intended coverage and the insurer would have stated all exclusions clearly and specifically and again getting back to reading the policy provisions together i kind of if that was the intent of zork that's what they claim that's not how these policy provisions read together i don't know how gifts reconciled with the coverage grant and i don't know how do you reconcile with no explosion you know being  in an insurance policy are to be resolved in favor of the insurer and must be strictly construed against the insurer a specially those bad up here to exclude coverage and where there are competing  in closing mr foley expected what all insured suspects expect when they buy an insurance policy they either power see they do typically pay the premiums a loss happens the insurance company pays insure for the damages and the insurer uses those proceeds to repair the damage zurich wants to turn this process into something totally different the insured still buys the policy and do it if we place a premium or when a loss happens the i would like to bypass for the facts but i think there are a few things i would like to address that and one of the arguments made by the public in that i also agree and americans are also agrees that this is but we we believe that the only reasonable and the trial court agree with this the only reasonable interpretation of this policy in the exclusion for water that over one that is striving to plus here is the twenty five thousand dollars limit for that type of damage that does not alter in any way the definition of a cover cause of loss under the policy it does not change the application of the exclusion but it dollars is that a dish will coverage and be purchased by the insurer and in this case that was purchased by the insured and americans are paid the policy limit for the pm which it occurred as a result of that risk that is in no way invalidating or accepting or ready revoking or with removing the exclusion for sewer drain overflow that's contained within the policy is a capitalized term ends defined in the policy and it carries a tremendous amount of weight in a policy that is a cover because of laws there are there are circumstances under which americans are will pay for damage to the cover cause of loss and that that is the one example of course is the sewer and drain overflow that we're talking about here today there are some other occasions where in the collapse coverage there are some circumstances under which it collapsed additional coverage or circuit certain circumstances in which the nature may be entitled to recovery but that does not render a cover cause of lost as that term is defined in the policy and that i ellipsis there you would fast forward to water that backs up or overflows from the sewer drain or something but you don't stop exactly if we did stop there maybe that would be an ambiguity because then you've got a solution and an but that's not covered it's not paid under the additional coverage that it's for construction form or debris removal that's part of the loss of a sustained by the plaintiff they had the is one of those occasions americans are under this policy paid the insured the full amount of its coverage  procreation for kids only case to which the guilty case the court is being guided by the concept of let's look at what was what the policy reflects was intended to be covered here there's we don't know if this policy is written very much the policies in for kids only and in which realty which recognize that that exclusion for sewer and drain back up creates a situation where a homeowner may suffer a loss that  policy to cover that risk and that can be part of the package of risks that are agreed to be insured between the insurer and the insurer that's what happened here that's what happened in fork it's only if it happened in wichita real and and that's it and that's exactly what happened here what we're asking the court to do is read these in harmony with the recognize that this additional coverage covers this area that would otherwise be uncovered but it does it render this cover because of loss for purposes of the policy doesn't change the definition of the cover cause of loss because it covered cause of loss is i it's not stricken or overwritten or superseded by any other language it that bad exclusion just acknowledges that the insurer may be insured may go out and purchase an additional coverage to cover that risk and if they do so they have the coverage that they covers then you've got exactly what that additional coverage provided which is twenty five thousand dollars and so that is back i don't believe is an exception to an we did have a period at the end of we will not pay and we didn't acknowledge that additional coverage which could be purchased then what would you do if there was additional coverage and  coverage pursuant to the terms of that additional coverage that they have tain it looks to us here on the facts that's the kind of loss that happened here americans are paid it's limit is trying to paint this additional coverage which is plain in this policy it's not an endorsement that was purchased separately to try get the dressin exclusion it's right here listed in section four under the cover under the heading coverage part of the coverage gray and it lists all these additional coverages they insure didn't go out and say this is excluded and now  it doesn't have to be again i'm not saying that mr foley gets he gets twenty five thousand dollars for his expenses that you have to do with the foundation digging through all the additional gravel that now he has to go in this twenty five thousand dollars this doesn't mean he doesn't get debris removal and construction forms and there is nothing in the language of the additional coverage for sewer apple that says and no other additional coverage is