The defendant's motion to dismiss an implied contract claim in a subrogation action was denied. Cumis Ins. Soc'y v. Count, 2018 U.S. Dist. LEXIS 118380 (D. Haw. July 16, 2018).

    Cumis issued a fidelity bond to Kauai Government Employee's Federal Credit Union (KGE). The bond provided coverage of losses incurred as a result…