SAN JOSE, Calif. - An insured seeking coverage for underlying lawsuits arising out of environmental contamination was not entitled to independent counsel because the insured failed to prove that the insurers had a conflict of interest in defending the insured, the Sixth District California Court of Appeal said Aug. 26 (Federal Insurance Co., et al. v. MBL Inc., et al., Nos. H036296, H036578, Calif. App., 6th Dist.; 2013 Cal. App. LEXIS 679).