According to the following fact pattern, assuming policy language or ambiguity, earth shifts causing the damage, what would a trial court brief say to convince the court that Ms. Shaunda Lear should be paid by the insurance company?

also requires reference to local jurisdiction case law/statutes that would be binding in court.

The client's name is Ms. Shaunda Lear. Ms. Lear has owned a ranch-style home in

Little Rock, Arkansas for five years. About six months ago, she noticed that the master

bathroom floor was spongy and sinking. Ms. Lear asked a local flooring contractor to

evaluate that floor. That expert determined that there was nothing wrong with the floor

but that perhaps a water leak under that floor might be causing it to sink. Afterward,

she contacted a plumber, who confirmed that, yes, there was a water leak under that

flooring.

Ms. Lear filed a claim against her homeowner's insurance company, The Insure-all

Corporation. (Insure-all provides homeowners coverage nationwide; it is headquartered

in Dover, Delaware.) However, Insure-all denied Ms. Lear's claim because an

engineering report for Ms. Lear's subdivision indicated that hers had been built on fill dirt, like all of the other

nearby homes. Construction over top of fill dirt is a

named exclusion to its policy with Ms. Lear.

Mr. Ring asked you to prepare a legal office memorandum addressing Ms. Lear's

primary issue: how to get Insure-all to pay for the underground plumbing leak and all of

the bathroom floor-related damage. Mr. Ring vaguely remembered reading about some

cases with somewhat similar facts, but at the moment, he cannot remember anything

about that case. Because he had to leave now to attend an out-of-town deposition, Mr.

Ring asked you to look for that case. You found it, analyzed it, and presented it to him in

a formal legal office memorandum.

...

Now we revisit a fact pattern first provided to you in LSTD 504 (Methods of Legal Research and Writing I). You reprise your earlier role as a paralegal working for an attorney (Mr. Bore Ring) at a small law firm (Howe, Borem, & Laff) in Little Rock, Arkansas. Back in LSTD 504, you had been assigned to research, analyze, and write a legal office memorandum for Mr. Ring concerning a then-new client's case. The underlying fact pattern is attached so that you can refresh your memory. Here is some updated information that you should use for this Week 4 Assignment in the LSTD 505 course.

Mr. Ring liked the legal office memorandum you submitted for Ms. Lear's case. He used your memo as a basis for his demand letter to try to get Insure-all to pay for the damage to Ms. Lear's home. Unfortunately, though, that letter did not convince the insurance company to compensate Ms. Lear at all. Therefore, Mr. Ring filed a lawsuit against Insure-all.

Now Mr. Ring wants you to help him with that case by preparing the first draft of the trial court brief. The primary goal of the trial court brief is to try to convince the judge that Insure-all should reimburse Ms. Lear for all of the expenses related to the underground plumbing leak and the related bathroom floor-related damage. Mr. Ring specifically asked that you prepare the brief by using the IRAC (Issue, Rule, Analysis, and Conclusion) method.

I am not intending to submit the tutors work as my own, rather providing the whole context of the question.