A Residential policy was issued covering a named insured and non-occupant additional insured. Named insureds damages are denied, however, payment for ALE and Content are made to additional insured who made no claim for such. Insurers recovery from negligent third party claimed monies paid out covered both insureds losses. I recently read a case, Essex v. Heck 186 Cal. App. 4th 1513; 112 Cal. Rptr. 3d 915; 2010 Cal. App, where the court denied subrogation, stating that Essex only had the right to assert claims for monies paid out on behalf of its insured. Does the same apply to a first party claim? Is an insurer obligated to correctly identify the amount paid to each insured for their respective losses and can an insurer name both insureds in their recovery when only one was paid?