NEW ORLEANS - An underlying complaint against a New Orleans nightclub sufficiently alleged bodily injury and property damage to trigger the club's insurer's duty to defend under a general liability policy, a Louisiana federal judge ruled Oct. 15, partly denying the insurer's motion to dismiss a bad faith claim against it (Bourbon Heat LLC v. Liberty Surplus Insurance Corp., No. 2:13-cv-02623, E.D. La.; 2013 U.S. Dist. LEXIS 148191).