Burr v. Lichtenheim
In Burr v. Lichtenheim, 190 Conn. 351, 460 A.2d 1290 (1983), the court held that it did not. It adopted the rule that, "in the absence of express contractual terms to the contrary, allowance of fees is limited to the defense of the claim which was indemnified and does not extend to services rendered in establishing the right to indemnification. . . . Courts have relied on encompassing language in the indemnity contract, usually specifically referring to attorney's fees, to find an express agreement to the contrary." Id., 363-64.