Insurance Law Alert

September 2016

In This Issue
New York Court Rules That Policyholder Is Responsible for Losses During
Periods When Insurance Was Unavailable
Addressing a matter of first impression under New York law, a New York appellate court ruledthat an insurer is not responsible for losses that occurred during periods when insurance wasunavailable in the marketplace. Keyspan Gas E. Corp. v. Munich Reins. Am., Inc., 2016 WL
4543479 (N.Y. App. Div. 1st Dep’t Sept. 1, 2016). (Click here for full article)

Simpson Thacher“[p]rovides highly
strategic knowledge witha devoted client service.”–The Legal 500
2016

Delaware Supreme Court Rejects “Significant Exposure To Asbestos”
Trigger Based On Continuous Nature Of Asbestos Injury
The Delaware Supreme Court reversed a trial court ruling that manufacturers of asbestoscontaining products may seek excess coverage only under policies that were in place during
claimants’ first inhalation, finding that excess coverage was triggered if any bodily injury
occurred during the policy periods. In re Viking Pump, Inc., 2016 WL 4771312 (Del. Sept. 12,2016). (Click here for full article)

Louisiana Supreme Court Rules That Defense Costs Should Be Prorated In
Continuous Injury Suit
Addressing a matter of first impression under Louisiana law, the Louisiana Supreme Court
ruled that costs to defend continuous injury suits should be allocated on a time-on-the-risk
pro rata basis, with pro ration to the insured for periods of no insurance. Arceneaux v. Amstar
Corp., 2016 WL 4699163 (La. Sept. 7, 2016). (Click here for full article)

New Jersey Court Rules That PRP Letter Is A “Suit” That Triggers The
Duty to Defend
Addressing a matter of first impression under New Jersey law, a New Jersey trial court ruledthat a PRP letter is a “suit” for purposes of triggering an insurer’s duty to defend. Cooper
Indus., LLC v. Employers Ins. of Wausau a Mut. Co., 2016 WL 4581506 (N.J. Super. Ct. Essex
Cnty. Aug. 30, 2016). (Click here for full article)

Eighth Circuit Rules That Damage Caused By Defective Bags Is A Covered
Occurrence
The Eighth Circuit ruled that losses caused by the use of defective plastic storage bags werecaused by a covered “occurrence” under a general liability policy. Decker Plastics Inc. v. West
Bend Mutual Ins. Co., 2016 WL 4409348 (8th Cir. Aug. 19, 2016). (Click here for full article)
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Simpson Thacher & Bartlett LLP

1

Pennsylvania Court Rules That Multiple Malpractice Claims Are A Single“Claim” For Purposes of Policy Limits
A Pennsylvania federal district court ruled that a malpractice lawsuit alleging several causes ofaction is a single “claim” under a professional liability policy, subject to a single per-claim limit.
Westport Ins. Corp. v. Mylonas, 2016 WL 4493192 (E.D. Pa. Aug. 26, 2016).
(Click here for full article)

Illinois Court Narrowly Construes Professional Services Exclusion, But
Upholds Insurer’s Coverage Denial On Late Notice Grounds
An Illinois federal district court ruled that a professional services exclusion did not apply to
an attorney’s law-related conduct but that there is no coverage based on the policyholder’suntimely notice. Sentinel Ins. Co., Ltd. v. Cogan, 2016 WL 4270213 (N.D. Ill. Aug. 15, 2016).
(Click here for full article)

Colorado Court Rules That Insurer Owes No Coverage or Defense for SEC
Investigation
A Colorado federal district court dismissed breach of contract and bad faith claims against
an insurer, finding that it had no duty to defend or indemnify the costs of responding to
a Securities and Exchange Commission investigation. Musclepharm Corp. v. Liberty Ins.
Underwriters, Inc., 2016 WL 4179784 (D. Colo. Aug. 4, 2016). (Click here for full article)

Nebraska Supreme Court Rules That Liability Policy Does Not CoverFaulty Workmanship Where Only Damage Is To Insured’s Work Product
The Nebraska Supreme Court ruled that a general liability insurer has no duty to provide
coverage for the costs of remediating faulty workmanship where there was no damage toproperty other than the insured’s own work. Drake-Williams Steel, Inc. v. Continental Cas.
Co., 83 N.W.2d 60 (2016). (Click here for full article)

Excess Judgment Is Not Prerequisite to Excess Insurer’s Equitable
Subrogation Claim Against Primary Insurer, Says California Appellate
Court
A California appellate court ruled that an excess insurer that has settled an insured’s liability
claims may bring an equitable subrogation claim against a primary insurer based on the
primary insurer’s unreasonable refusal to settle within policy limits. Ace American Ins. Co. v.
Fireman’s Fund Ins. Co., 206 Cal. Rptr. 3d 176 (Cal. Ct. App. 2d Dist. 2016).
(Click here for full article)

Third Circuit Addresses Minimum Amount in Controversy Requirement
for Insurer’s Declaratory Judgment Action
The Third Circuit ruled that in determining whether an insurer has alleged the minimum
amount in controversy for purposes of diversity jurisdiction over a declaratory judgment
action, the court can consider the total potential damages owed to each class member in anunderlying class action, as well as the costs of defending the underlying action. Auto-Owners
Ins. Co. v. Stevens & Ricci Inc., 2016 WL 4547641 (3d Cir. Sept. 1, 2016).
(Click here for full article)2

Allocation Alert:

Trigger Alert:

Addressing a matter of first impression under
New York law, a New York appellate court
ruled that an insurer is not responsible forlosses that occurred during periods wheninsurance was unavailable in the marketplace.
Keyspan Gas E. Corp. v. Munich Reins. Am.,
Inc., 2016 WL 4543479 (N.Y. App. Div. 1st
Dep’t Sept. 1, 2016).

The Delaware Supreme Court reversed a trial
court ruling that manufacturers of asbestoscontaining products may seek excess coverage
only under policies that were in place during
claimants’ first inhalation, finding that excess
coverage is triggered if any bodily injury
occurred during the policy periods. In re
Viking Pump, Inc., 2016 WL 4771312 (Del.
Sept. 12, 2016).

New York Court Rules That
Policyholder Is Responsible forLosses During Periods When
Insurance Was Unavailable

Keyspan filed a declaratory judgment action
seeking indemnification from Century forlong-term environmental clean-up costs. A
New York trial court ruled that Century’s
indemnity obligations should be determinedby a pro rata time-on-the-risk allocation andthat Keyspan is responsible for the share of
liability attributable to periods in which it did
not purchase insurance that was otherwise
available in the marketplace. However, thetrial court held that liability for periods wheninsurance was unavailable should be allocatedto Century. The appellate court reversed.

The appellate court ruled that Century has
no obligation to indemnify Keyspan forlosses outside its policy periods. The court
relied on policy language limiting coverage
to occurrences or property damage “during
the policy period,” explaining that there
was no basis for creating an “unavailability
exception” to pro rata allocation. The
court also rejected Keyspan’s equity-based
arguments, stating that “spreading risk
should not by itself serve as a legal basis
for providing free insurance to an insured.”As the court observed, courts in otherjurisdictions have issued mixed decisions as
to whether pro-ration to the insured is subject
to an unavailability exception.

Delaware Supreme Court Rejects“Significant Exposure To Asbestos”
Trigger Based On Continuous
Nature Of Asbestos Injury

A Delaware trial court ruled that Viking
Pump could pursue excess coverage only
under policies that were in effect when
the underlying asbestos claimants werefirst significantly exposed to asbestos. The
Delaware Supreme Court overturned thatruling, holding it inconsistent with New
York’s “injury in fact” trigger law. Instead, thecourt held that, for policy coverage purposes,
bodily injury first occurs “upon cellularand molecular damage caused by asbestos
inhalation, and such cellular and moleculardamage occurs during each and every periodof an asbestos claimant’s significant exposure
to asbestos and continues thereafter” (italics
in original). The court explained that its
ruling reflected the fact that asbestos-related
injuries occur gradually and continuously
after an individual’s initial exposure. Notably,
the court focused on “significant exposure” insetting forth the appropriate trigger, which
may prompt future disputes as to what degreeof exposure so qualifies.
The court addressed several other issues,
including the excess insurers’ duties todefend (which varied based on applicablepolicy language) and the post-loss transfer of
insurance rights from predecessor companies(which was found valid notwithstanding antiassignment clauses).
The trigger ruling is the latest in a series ofsignificant coverage decisions in this case.
As discussed in our May 2016 Alert, the New
York Court of Appeals, answering certified
questions, recently held that under applicablepolicy language, the manufacturers’
policies were subject to all sums allocationand that excess policy language required
vertical exhaustion.
3

Duty To
Defend Alerts:

Louisiana Supreme Court Rules
That Defense Costs Should Be
Prorated In Continuous Injury Suit
Addressing a matter of first impression
under Louisiana law, the Louisiana Supreme
Court ruled that costs to defend continuous
injury suits should be allocated on a timeon-the-risk pro rata basis, with pro ration
to the insured for periods of no insurance.
Arceneaux v. Amstar Corp., 2016 WL
4699163 (La. Sept. 7, 2016).
A Louisiana trial court and appellate court
both ruled that Continental was required
to provide American Sugar with a complete
defense in an underlying suit alleging ongoingbodily injury, notwithstanding that its
policies covered only twenty-six months of
the approximate 60 year period of exposure.
The Louisiana Supreme Court reversed,
ruling that Louisiana’s endorsement of pro
rata allocation for indemnity costs applied todefense obligations as well. Joining a growing
number of jurisdictions, the court relied on
the “during the policy period” policy language
in concluding that pro rata allocation of
defense costs is warranted. The court stated:“While the duty to defend is broader thanthe duty to indemnify, neither obligation isbroader than the policy’s coverage period in
the context of long latency disease cases thattrigger occurrence-based policies.” On thisbasis, the court held that American Sugar isrequired to pay for its own defense during
years in which it did not have insurance
because “[t]o hold otherwise would entitle
an insured to receive coverage for a period inwhich it did not pay a premium.”

New Jersey Court Rules That PRP
Letter Is A “Suit” That Triggers The
Duty to Defend
Addressing a matter of first impression under
New Jersey law, a New Jersey trial court ruledthat a PRP letter is a “suit” for purposes oftriggering an insurer’s duty to defend. Cooper
Indus., LLC v. Employers Ins. of Wausau aMut. Co., 2016 WL 4581506 (N.J. Super. Ct.
Essex Cnty. Aug. 30, 2016).

The Environmental Protection Agency
identified Cooper as a “potentially responsible
party” for contamination at a particularsite. The notice alleged that Cooper was
responsible for remediation of the site
and requested participation in a groupsettlement. The EPA warned that Cooper’s
failure to comply would result in enforcement
proceedings under CERCLA. Cooper soughta defense from OneBeacon under a generalliability policy. OneBeacon refused to defend
on the basis that no “suit” had been filed,
as required by the policy. Cooper thereaftersought a declaration that OneBeacon was
required to pay the costs of defending the PRP
letter, among other things. The court granted
Cooper’s partial summary judgment motion,
ruling that a PRP letter triggers an insurer’s
duty to defend.

The court rejected OneBeacon’s “plain
meaning” approach to the term “suit” andinstead joined the “majority of courts” inconcluding that a PRP letter is a suit for
purposes of an insurer’s defense obligation. In
particular, the court cited the Texas Supreme
Court’s decision in McGinnes Indus. Maint.
Corp. v. Phoenix Ins. Co., 477 S.W.3d 786(Tex. 2015) (discussed in our July/August
2015 Alert), which reasoned that EPA
proceedings are not merely the functional
equivalent of a suit, but rather “are the suit
itself, only conducted outside a courtroom.”
The court expressly distinguished otheradministrative actions that involve voluntary
conduct, which are not considered to be“suits” under New Jersey law, noting that PRP
letters are coercive in nature.

4Occurrence Alert:

Eighth Circuit Rules That Damage
Caused By Defective Bags Is A
Covered Occurrence
Reversing an Iowa district court decision,
the Eighth Circuit ruled that losses causedby the use of defective plastic storage bags
were caused by a covered “occurrence” undera general liability policy. Decker Plastics
Inc. v. West Bend Mutual Ins. Co., 2016 WL
4409348 (8th Cir. Aug. 19, 2016).
Decker, a manufacturer of plastic storage
bags, was sued by a landscape supplier after
it discovered that the bags were defective anddeteriorated in sunlight. The deterioration
caused small pieces of plastic to commingle
with landscaping materials. As a result,the company had to clean materials from
customers’ properties, purchase replacement
bags from another supplier, and clean its own
premises. Decker settled the lawsuit with thelandscape supplier and sought coverage from
West Bend. The insurer denied coverage,
arguing that there was no “occurrence” under
the policy. An Iowa district court agreed andgranted West Bend’s summary judgment
motion. The Eighth Circuit reversed.
Citing precedent in the defective construction
context, the Eighth Circuit ruled that theclaims alleged an occurrence because thedefective bags caused damage to property
other than the bags themselves. The court
stated: “We have repeatedly construed‘occurrence’ to cover damages to property
that was not the insured’s work product.”
The court remanded the matter to the district
court for a determination of whether coverage
was nonetheless barred by a “your product” oran impaired-property exclusion.

Coverage Alerts:

Pennsylvania Court Rules That
Multiple Malpractice Claims Are
A Single “Claim” For Purposes of
Policy Limits
A Pennsylvania federal district court ruledthat a malpractice lawsuit alleging several
causes of action is a single “claim” undera professional liability policy, subject to asingle per-claim limit. Westport Ins. Corp. v.
Mylonas, 2016 WL 4493192 (E.D. Pa. Aug.
26, 2016).
The coverage dispute arose out of malpracticeclaims filed against an attorney. A jury foundin the plaintiff’s favor and awarded $525,000
in damages. The insurer brought a declaratory
judgment action, seeking a ruling that its
liability was limited to $500,000 (the perclaim limit under the policy). Defense costs
eroded policy limits, and only limited monies
were available to pay the judgment because
defense costs had significantly eroded the
per claim limit. To maximize his recovery,
the underlying plaintiff argued that themalpractice suit arose from multiple claims
because he had asserted multiple causes ofaction, requiring the insurer to provide up to$1 million in coverage (the aggregate limit).
The court ruled that the malpractice suit isa single “claim” under the policy, defined as“a demand made upon any INSURED for
LOSS . . . including but not limited to, serviceof suit . . .” The court rejected the argumentthat the lawsuit constituted multiple claims
because it alleged “several unrelated breachesof the standard of care, which caused separate
and distinct injuries.” The court further
rejected the contention that the issue was oneof fact for the jury based on expert testimony.
The court reasoned that “the number of5

counts” in a complaint is not dispositive andthat “regardless of how [the claimant] frames
the contentions made in the underlying
lawsuit for the purpose of interpreting theprofessional liability policy . . . the demand in
the form of service of the suit constitutes only
one claim under the Policy . . . .”Illinois Court Narrowly Construes
Professional Services Exclusion,
But Upholds Insurer’s Coverage
Denial On Late Notice Grounds
An Illinois federal district court ruled that a
professional services exclusion did not apply
to an attorney’s law-related conduct because
he was not rendering legal services. However,the court nonetheless held that there is nocoverage based on the policyholder’s untimely
notice. Sentinel Ins. Co., Ltd. v. Cogan, 2016
WL 4270213 (N.D. Ill. Aug. 15, 2016).
The Cogan law firm was sued for defamation
by another law firm. The defamation claims
were based on an email a Cogan attorneysent to a judge’s law clerk alleging ethical andprofessional misconduct by an attorney at theplaintiff law firm. The Cogan law firm sought
coverage from Sentinel under a generalliability policy. Sentinel sued, seeking a rulingthat it had no duty to defend or indemnify
based on a professional services exclusion anduntimely notice. The court rejected the firstbasis for denial, but upheld the latter.
The professional services exclusion applied
to “any ‘personal and advertising injury’arising out of the rendering of or failure to
render professional services as a lawyer.”
The court ruled that the Cogan attorney was
not rendering professional legal services
when he sent the email. The court explainedthat although the attorney was acting as an
officer of the court when he reported thealleged misconduct and “spoke as a lawyer,”
he was not rendering a professional service
because he was not representing a clientin connection with the email. The court
stated that “in conveying his concerns tothe court, Papin called upon his specialized
knowledge and training as a lawyer. But a
service to the profession is not the same as aprofessional service.”
With respect to Sentinel’s late notice defense,
the court held that the law firm forfeitedcoverage by waiting approximately eightmonths to provide notice of the underlying

suit. Illinois law requires considerationof several factors relating to the timing of
the notice, including the policyholder’ssophistication, diligence, and awarenessof events triggering notice. Citing to thelaw firm’s legal expertise, its awareness ofthe events triggering notice, and its lack ofdiligence with respect to coverage analysis,
the court found the delay in notice untimely
as a matter of law.
The Cogan law firm filed a notice of appeal in
the Seventh Circuit this month. We will keep
you posted on any updates in this matter.

Colorado Court Rules That Insurer
Owes No Coverage or Defense for
SEC Investigation
A Colorado federal district court dismissed
breach of contract and bad faith claims
against an insurer, finding that it had no
duty to defend or indemnify the costs of
responding to a Securities and Exchange
Commission investigation. MusclepharmCorp. v. Liberty Ins. Underwriters, Inc., 2016
WL 4179784 (D. Colo. Aug. 4, 2016).
MusclePharm sought coverage under aLiberty policy for the fees and costs incurredin responding to an SEC investigation. The
SEC initially notified MusclePharm that itwas conducting an inquiry into the company’s
operations and requested the production ofcertain documents. The SEC later issued anorder stating that it had “information thattends to show” possible violations of federal
securities laws. Liberty denied coverage as
to both the initial letter and the subsequent
order on the basis that they did not amountto a “Claim” for a “Wrongful Act.” Thecourt agreed.
The policy defined “Wrongful Act” as “anyactual or alleged error, misstatement,
misleading statement, act, omission, neglect,or beach of duty, actually or allegedly
committed or attempted . . . .” The court
reasoned that this provision requires “apositive assertion that the implicated error
or omission is believed to have actuallyoccurred, even if still subject to proof.” Thecourt held that the SEC order did not meetthis requirement because it did not allege
that wrongdoing had transpired, but merely
authorized the SEC to investigate further todetermine whether “hypothetical violations
did in fact occur.” In reaching this conclusion,
6

Subrogation Alert:
Excess Judgment Is Not
Prerequisite to Excess Insurer’s
Equitable Subrogation Claim
Against Primary Insurer, Says
California Appellate Court

the court relied on provisional language in
the SEC order (e.g., “if true tends to show”;“possible violation[s]”; and violations which“may have” occurred). As discussed in our
May 2013 Alert, the Sixth Circuit reached asimilar conclusion in Employers’ Fire Ins.
Co. v. ProMedica Health Sys., Inc., 2013 WL
1798978 (6th Cir. Apr. 30, 2013), involving
an insurer’s duty to defend a Federal Trade
Commission investigation.
This month, MusclePharm moved forreconsideration. We will keep you posted on
further developments in this matter.

Nebraska Supreme Court Rules
That Liability Policy Does Not
Cover Faulty Workmanship
Where Only Damage Is To
Insured’s Work Product
The Nebraska Supreme Court ruled thata general liability insurer has no duty toprovide coverage for the costs of remediating
faulty workmanship where there is nodamage to property other than the insured’s
own work. Drake-Williams Steel, Inc. v.
Continental Cas. Co., 83 N.W.2d 60 (2016).
The court explained that liability policies are
not intended to protect against “businessrisks,” which include expenditures made tocorrect a policyholder’s own defective work.
The court explained that coverage may be
implicated where faulty workmanship has
allegedly caused damage to other structures
or property, separate and apart from theinsured’s own work. As discussed in previous
Alerts, courts across jurisdictions employ avariety of approaches in evaluating whether
faulty workmanship claims fall within thescope of general liability coverage. See June2015 Alert; May, October and December 2013
Alerts; February 2011 Alert; April 2010 Alert.

A California appellate court ruled that an
excess insurer that has settled an insured’s
liability claims may bring an equitable
subrogation claim against a primary insurer
based on its unreasonable refusal to settle
within policy limits. Ace American Ins. Co.
v. Fireman’s Fund Ins. Co., 206 Cal. Rptr. 3d
176 (Cal. Ct. App. 2d Dist. 2016).
A worker sued its employer for injuries
sustained during employment. The employer
was insured under a primary policy with
Fireman’s Fund and an excess policy with
Ace. Fireman’s Fund defended and ultimately
settled the case, with participation andcontribution from Ace. Ace sued Fireman’s
Fund for equitable subrogation, alleging
that the worker had offered to settle thecase within primary policy limits and that
Fireman’s Fund unreasonably rejected thoseoffers. As a result, Ace was obligated tocontribute to the ultimate settlement, which
exceeded primary policy limits. Fireman’s
Fund responded by arguing that Ace’s
claim was not viable because there was noexcess judgment in the underlying personal
injury suit. A California trial agreed, and theappellate court reversed.
The court noted that the purpose of requiring
an underlying judgment is “simply to ensurethat a plaintiff has a reliable basis for alleging
that damages have resulted from the insurer’s
alleged breach of the duty to settle withinpolicy limits . . . .” The court explained thatwhile “[a] judgment may constitute reliable
evidence of damages,” “it does not followthat a judgment is the only manner bywhich an insured or subrogee may provedamages resulting from an unreasonable
failure to settle within policy limits.” Where,
as here, the primary insurer participated inand consented to the settlement, the court
held that the excess settlement constitutes
sufficient allegations of damages. The court
distinguished cases in which the primary
insurer did not participate in the settlement,
which gave rise to concerns about collusion
between the insured and excess insurer.

7Jurisdictional
Alert:

controversy. See 28 U.S.C. § 1332(a). In
particular, the insured argued that although
the underlying suit ultimately settled for$2 million, each class member’s claims fell
below $75,000. As the insured noted, underthe “anti-aggregation” rule adopted by theThird Circuit, the claims of separate plaintiffs
cannot be aggregated to satisfy the amount incontroversy. The court rejected this argument.

The Third Circuit ruled that in determining
whether an insurer has alleged the minimum
amount in controversy for purposes ofdiversity jurisdiction over a declaratory
judgment action, the court can consider the
potential damages owed to each class member
in an underlying class action, as well as thecosts of defending the underlying action.
Auto-Owners Ins. Co. v. Stevens & Ricci Inc.,
2016 WL 4547641 (3d Cir. Sept. 1, 2016).

The Third Circuit explained that for
declaratory judgment actions that do not
involve monetary damages, the amount incontroversy is “measured by the value of theobject of the litigation.” The court held thatthe “object of the litigation” before it was
the total amount that Auto-Owners could
owe, including both defense and indemnity
costs. The court rejected the notion that theaction was “properly viewed as a dispute
between Auto-Owners and the many
class members – which would give rise toaggregation problems . . . .” Rather, the court
explained, this was a “unitary controversy”
relating to overall coverage obligations. The
court recognized that its ruling “results ina situation in which an insurer can invoke
federal jurisdiction in a declaratory judgment
action while class members cannot.”Third Circuit Addresses
Minimum Amount in Controversy
Requirement for Insurer’s
Declaratory Judgment Action

Auto-Owners filed a declaratory judgment
action seeking a ruling that it has no
obligation to defend or indemnify its
insured in connection with a TCPA classaction suit and settlement. A Pennsylvania
federal district court granted the insurer’ssummary judgment motion, ruling that thetransmission of unsolicited faxes was notcovered “advertising injury” or property
damage caused by an occurrence. On appeal,
the insured argued that the district court
lacked diversity jurisdiction over the disputebecause Auto-Owners had not alleged therequisite $75,000 minimum amount in

Co-defendant Hymed Group Corporation filed
a petition for en banc rehearing this month.
We will keep you posted on any developmentsin this matter.

8

Simpson Thacher has been an international leader in the practice of insurance and reinsurance law for
more than a quarter of a century. Our insurance litigation team practices worldwide.

David J. Woll
+1-212-455-3136
dwoll@stblaw.com

Bryce L. Friedman+1-212-455-2235
bfriedman@stblaw.com

Deborah L. Stein+1-310-407-7525
dstein@stblaw.com

Mary Beth Forshaw+1-212-455-2846
mforshaw@stblaw.com

Michael D. Kibler+1-310-407-7515
mkibler@stblaw.com

Craig S. Waldman+1-212-455-2881
cwaldman@stblaw.com

Andrew T. Frankel+1-212-455-3073
afrankel@stblaw.com

Michael J. Garvey+1-212-455-7358
mgarvey@stblaw.com

Susannah S. Geltman+1-212-455-2762
sgeltman@stblaw.com

Lynn K. Neuner+1-212-455-2696
lneuner@stblaw.com

Tyler B. Robinson+44-(0)20-7275-6118
trobinson@stblaw.com

Elisa Alcabes+1-212-455-3133
ealcabes@stblaw.com

Chet A. Kronenberg+1-310-407-7557
ckronenberg@stblaw.com

George S. Wang
+1-212-455-2228
gwang@stblaw.com

Summer Craig+1-212-455-3881
scraig@stblaw.com

This edition of the
Insurance Law Alert was
prepared by Mary Beth Forshaw
mforshaw@stblaw.com /+1-212455-2846 and Bryce L. Friedman
bfriedman@stblaw.com /+1-212-4552235 with contributions
by Karen Cestarikcestari@stblaw.com.

The contents of this publication are for informational purposes only. Neither this publication nor the
lawyers who authored it are rendering legal or other professional advice or opinions on specific facts
or matters, nor does the distribution of this publication to any person constitute the establishment of an
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Please click here to subscribe to the Insurance Law Alert.
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