Scottsdale Ins. Co. v. Cendejas
In Scottsdale Ins. Co. v. Cendejas, 220 Ariz. 281, 285,18, 205 P.3d 1128, 1132 (App. 2009), the court refused to revive a facially vague notice of nonparty at fault by reference to disclosures because the disclosures themselves were so vague that they provided no theory of fault. See 220 Ariz. at 286,22, 205 P.3d at 1133.
The disclosure in Cendejas merely stated that the nonparty at fault "may have installed building components in such a manner as to create the condition which caused or contributed to the fire." Id.