Insurance Law Alert

January 2018

In This Issue
Florida Supreme Court Rules That Statutory Process For Construction
Defect Claims Is A “Suit” Triggering Insurer’s Duty To Defend
The Florida Supreme Court ruled that a statutory process for resolving construction defectclaims is a “suit” that triggers an insurer’s duty to defend under a general liability policy.
Altman Contractors, Inc. v. Crum & Forster Specialty Ins. Co., 2017 WL 6379535 (Fla. Dec. 14,2017). (Click here for full article)“We go to themfor their experience;
their work productis flawless.”–Chambers USA 2017,
quoting a client

Two Courts Rule That Reservation Of Rights Does Not Give Rise To
Conflict Of Interest
An Illinois appellate court and a California federal district court both ruled that an insurer’s
reservation of rights did not create a conflict of interest entitling the policyholder toindependent counsel at the insurer’s expense. Bean Products, Inc. v. Scottsdale Ins. Co., 2018
WL 522627 (Ill. App. Ct. Jan. 22, 2018); Tokio Marine Specialty Ins. Co. v. City of Laguna
Beach, 2017 WL 6512226 (C.D. Cal. Dec. 18, 2017). (Click here for full article)

Policyholder’s Misrepresentation In Application Warrants Rescission
Notwithstanding Confusing Question, Says Ninth Circuit
The Ninth Circuit ruled that an insurer was entitled to rescind a policy based on thepolicyholder’s misrepresentation in the application, notwithstanding that the applicationquestion at issue was grammatically confusing. Western World Ins. Co. v. Professional
Collection Consultants, 2018 WL 259309 (9th Cir. Jan. 2, 2018). (Click here for full article)

West Virginia Court Denies Insurer’s Claim For Defense Cost
Reimbursement Following Rescission Of Policy
A West Virginia federal district court ruled that rescission of an insurance policy was warranted
but that the insurer was not entitled to reimbursement of defense costs expended by the
insurer prior to rescission. ALPS Property & Casualty Ins. Co. v. Turkaly, 2018 WL 385195(S.D.W.Va. Jan. 11, 2018). (Click here for full article)

Finding That NASDAQ Investors Are “Customers,” Second Circuit Rules
That Professional Services Exclusion Bars Coverage For Class Action
Settlement
The Second Circuit ruled that a professional services exclusion relieved D&O insurers fromfunding an underlying settlement in a class action suit against NASDAQ. Beazley Ins. Co., Inc.
v. Ace American Ins. Co., 2018 WL 492693 (2d Cir. Jan. 22, 2018). (Click here for full article)



Simpson Thacher & Bartlett LLP

1

Mississippi Court Allows Bad Faith Claim To Proceed Despite Dismissal Of
Breach Of Contract ClaimA Mississippi federal district court refused to dismiss a bad faith claim against an insurer,
notwithstanding the dismissal of a breach of contract claim arising out of the same underlying
conduct. Heritage Props., Inc. v. Ironshore Specialty Ins. Co., 2018 WL 506483 (S.D. Miss.
Jan. 22, 2018). (Click here for full article)

Applying “Triggering” Approach, West Virginia Court Rules That Sexual
And Physical Abuse Claims Constitute Multiple Occurrences
A West Virginia federal district court ruled that claims alleging sexual and physical abuse,malnourishment and educational neglect constitute multiple occurrences. Brotherhood Mutual
Ins. Co. v. Bible Baptist Church, 2017 WL 6061979 (S.D.W.Va. Dec. 7, 2017). (Click here forfull article)

Eleventh Circuit Rules That Additional Insured Endorsement Limits
Coverage To Liability Caused By Named Insured
The Eleventh Circuit ruled that an additional insured endorsement provides coverage only
when underlying liability was caused in whole or in part by the named insured. Employers
Mutual Cas. Co. v. Shivam Trading, Inc., 2018 WL 365216 (11th Cir. Jan. 11, 2018). (Click here
for full article)

Florida Court Rules That Insurer Implicitly Waived Equitable Subrogation
Claim
A Florida district court dismissed an equitable subrogation claim brought by one insurer
against another, finding that the insurer seeking contribution failed to establish coverage under
the other insurer’s policy, and in any event, had waived its right to seek such contribution.
Privilege Underwriters Reciprocal Exchange v. The Hanover Insurance Grp., 2018 WL
477277 (S.D. Fla. Jan. 19, 2018). (Click here for full article)2

Duty To Defend
Alert:

Florida Supreme Court Rules That
Statutory Process For Construction
Defect Claims Is A “Suit” Triggering
Insurer’s Duty To Defend
Answering a question certified by the
Eleventh Circuit, the Florida Supreme Court
ruled that a statutory process for resolving
construction defect claims is a “suit” that can
trigger defense obligations under a generalliability policy. Altman Contractors, Inc. v.
Crum & Forster Specialty Ins. Co., 2017 WL
6379535 (Fla. Dec. 14, 2017).
Altman, the general contractor for theconstruction of Sapphire Condominiums, wasinsured under consecutive general liability
policies issued by Crum & Forster. During thecoverage period, Sapphire served Altman withnumerous notices of claim under chapter 558,
Florida Statutes, which sets forth a process
for resolving construction defect claims andis a condition precedent to filing a lawsuit.
Altman sought defense and indemnity from
Crum & Forster, which the insurer denied
on the basis that the statutory process was
not a “suit” under the policy, defined as “acivil proceeding in which damages . . . arealleged,” an arbitration, or “[a]ny otheralternative dispute resolution proceedingin which such damages are claimed and towhich the insured submits with our consent.”
Thereafter, Altman sought a declaration that
Crum & Forster was obligated to defend andindemnify the claims and moved for partial
summary judgment on whether the duty to
defend was triggered by the initiation of thestatutory procedure.
After the Florida district court ruled that thechapter 558 process was not a “suit,” Altman
appealed to the Eleventh Circuit, which
certified the following question: “Is the noticeand repair process set forth in chapter 558,
Florida Statutes, a suit within the meaning of
the commercial general liability policy issued
by C&F to Altman?” The Florida Supreme
Court accepted certification and answered thequestion in the affirmative.
The Florida Supreme Court ruled that thechapter 558 process is not a “civil proceeding”
under the policy because, although the statuterequires a claimant to serve a notice of claim

prior to filing suit, the recipient’s participation
is not mandatory and the process does nottake place in a court of law or involve any
type of adjudicatory body. However, the court
concluded that the chapter 558 process does
fall within the scope of “any other alternative
dispute resolution proceeding,” noting that
the Legislature expressly described the statuteas an “effective alternative dispute resolution
mechanism.” The court also held that thedamages component of the suit requirement
was met because chapter 558 provides fordamage awards.
The court declined to address whether Crum
& Forster had consented to the proceeding(as required by the policy’s definition of“suit” to trigger the insurer’s duty to defend),
explaining that it was outside the scope of thecertified question. The court remanded thematter for a factual determination.

Conflict Of Interest
Alert:
Two Courts Rule That Reservation
Of Rights Does Not Give Rise To
Conflict Of Interest

An Illinois appellate court affirmed a trial
court decision holding that an insurer’s
reservation of rights as to a punitive damage
claim did not automatically create a conflictof interest entitling the policyholder toindependent counsel at the insurer’s expense.
Bean Products, Inc. v. Scottsdale Ins. Co.,2018 WL 522627 (Ill. App. Ct. Jan. 22, 2018).
A suit filed against Bean Products alleged thatit marketed and sold home-gym products
in violation of another entity’s copyrightand trademark. Bean retained counsel, whoprovided notice of the suit to Scottsdale,
Bean’s liability insurer. Scottsdale appointed
counsel to defend the underlying suitand issued a limited reservation of rights
with respect to the underlying claim forpunitive and exemplary damages. Scottsdale
further advised that it was not waiving“any additional defenses which further
investigation will reveal.” Bean argued thatthe reservation of rights created a conflict ofinterest entitling Bean to retain independent
counsel. After the underlying suit was settled,
Bean sued Scottsdale seeking a declaration3

Ins. Co. v. City of Laguna Beach, 2017 WL
6512226 (C.D. Cal. Dec. 18, 2017), ruling thata reservation of rights as to a “your insured
location” policy exclusion did not createan actual conflict of interest between theparties even though the location of the causeof damage was at issue in the underlying
dispute.

that Scottsdale was obligated to reimburse
Bean for the fees incurred in paying forindependent counsel. A trial court ruled infavor of Scottsdale, finding no conflict ofinterest and no right to independent counsel.
The appellate court affirmed.
Under Illinois law, a conflict exists if “theinsurer’s interests would be furthered byproviding a less than vigorous defense to
the [underlying] allegations.” Bean argued
that Scottsdale had an interest in providing
a less than vigorous defense to the punitive
damages claim because any such damages
would be outside the scope of coverage. The
court disagreed, finding that the punitive
damages issue created only an “attenuated,hypothetical conflict” rather than an actualone. The court distinguished precedent inwhich a reservation of the right to disclaim
coverage for punitive damages gave rise toa conflict of interest where the underlying
plaintiff had sought minimal compensatory
damages and substantial punitive damages.
Noting that the underlying complaint against
Bean did not demand “a disproportionate
ratio of compensatory to punitive damages,”the court emphasized that a reservation
as to a punitive damage claim does not
automatically give rise to a conflict under
Illinois law.
The court also rejected Bean’s assertion
that the “open ended” nature of Scottsdale’s
reservation of rights created a conflict ofinterest. Bean contended that the reservation
allowed Scottsdale to “lay the groundwork”
for a later coverage denial while still
controlling the defense of the underlying suit.
Dismissing these contentions, the court heldthat Bean failed to show a divergence in theparties’ interests and, at best, demonstrated
only a remote possibility that a conflict
could develop.
A California federal district court reached thesame conclusion in Tokio Marine Specialty

The City of Laguna Beach sought defense
and indemnity from Tokio Marine forunderlying claims arising out of a sewer
backup. Tokio Marine agreed to defend undera reservation of rights. In its reservation,
Tokio Marine cited several possible bases for
non-coverage, including the contention thatthe contamination at issue did not satisfy thepolicy’s “your insured location” requirement.
In response, the City demanded that Tokio
Marine pay for independent counsel based ona conflict of interest. The City argued that a
conflict existed because the precise locationof the sewer blockage was a primary issue indispute in both the underlying and coverage
actions. The court disagreed and denied theCity’s partial summary judgment motion.
Section 2860 of the California Civil Coderequires an insurer to provide independent
counsel to the insured if a conflict of interest
exists. The court concluded that no suchconflict existed here because the interestsof the City and Tokio Marine were aligned
in disputing the City’s liability. The court
explained:
For an actual conflict to materialize,
Tokio Marine’s appointed counsel
would have to advocate that a blockagein the main line, rather than a trunk
line, was the causal factor leading to
the backup. Such a position would
necessarily concede the City’s liability.
The City provides no evidence tosupport why appointed counsel would
take such a position when a defensethat denies the City’s liability would
both align with the interests of the Cityand Tokio Marine and fulfill counsel’s
fiduciary duties to both clients.
The court also rejected the City’s contention
that a conflict existed by virtue of thedeclaratory judgment action filed by Tokio
Marine against the City to determine its
rights and obligations, noting that “litigation
alone does not, as a matter of law, create aconflict of interest that entitles the City to
independent counsel.”4

Rescission Alerts:

Policyholder’s Misrepresentation
In Application Warrants Rescission
Notwithstanding Confusing
Question, Says Ninth Circuit
The Ninth Circuit ruled that an insurer
was entitled to rescind a policy based on
the policyholder’s misrepresentation in
the application, notwithstanding thatthe application question at issue wasgrammatically confusing. Western World Ins.
Co. v. Professional Collection Consultants,
2018 WL 259309 (9th Cir. Jan. 2, 2018).
In 2013, FBI agents executed a search warrant
at the offices of Professional Collection
Consultants (“PCC”) and issued subpoenas
to several PCC employees. In 2014, PCC
applied for and obtained D&O insurance
from Western World Insurance. In 2015,
Western sought to rescind the policy based ona material misrepresentation relating to thefollowing question: “None of the individuals
to be insured under any Coverage Part (the‘Insured Persons’) have a basis to believethat any wrongful act, event, matter, fact,
circumstance, situation, or transaction, mightreasonably be expected to result in or be
the basis of a future claim?” PCC answered“no” to this question. A California federal
district court granted Western’s summary
judgment motion for rescission and the Ninth
Circuit affirmed.
The Ninth Circuit held that rescission wasappropriate because PCC’s answer was amaterial misrepresentation in light of theprior FBI investigation. The court rejected
PCC’s contention that the response was
not a misrepresentation because whenread literally, the negative response wasgrammatically accurate (i.e., PCC was awareof circumstances that could lead to a claim).
The court reasoned that the overall context ofthe question indicated that the question was
asking about possible claims, even though
it was inartfully worded. In particular, thecourt noted that the application instructions

indicated that a “yes” response would require
additional information and could affect theterms and conditions offered. The court also
rejected PCC’s assertion that the answer was
immaterial because the question was only
required for applicants seeking increased
policy limits. Given the relevance of the FBI
investigation to the insurer’s assumptionof risk, the court deemed the informationmaterial as a matter of law.

West Virginia Court Denies
Insurer’s Claim For Defense
Cost Reimbursement Following
Rescission Of Policy
A West Virginia federal district court ruledthat rescission of an insurance policy was
warranted but that the insurer was notentitled to reimbursement of defense costs
expended by the insurer prior to rescission.
ALPS Property & Casualty Ins. Co. v.
Turkaly, 2018 WL 385195 (S.D.W.Va. Jan.
11, 2018).
Attorney Michael Turkaly sought coverage
from professional liability insurer ALPS formalpractice claims filed against him during
the policy period. ALPS initially defended
Turkaly under a reservation of rights, but latersought to rescind the policy based on alleged
misrepresentations in the application. ALPS
filed the instant suit, seeking a declaration
as to rescission and reimbursement ofcosts incurred in defending Turkaly in theunderlying suit.
The court ruled that rescission was proper
under West Virginia law because Turkaly
made material misrepresentations in his
policy—namely, that he was unaware of any
facts that could form the basis of a claim
against him, when in actuality, he had
knowledge of the underlying suit against him.
However, the court denied ALPS’s claim that
it was entitled to reimbursement of defense
costs under the policy. The court reasoned
that “[b]ecause the 2016 Policy is rescinded
and void ab initio, it cannot form the basis of
liability, for either ALPS or Michael Turkaly.”5

Coverage Alert:

Finding That NASDAQ Investors
Are “Customers,” Second Circuit
Rules That Professional Services
Exclusion Bars Coverage For Class
Action Settlement
The Second Circuit ruled that a professional
services exclusion relieved D&O insurers fromfunding an underlying settlement in a classaction suit against NASDAQ. Beazley Ins.
Co., Inc. v. Ace American Ins. Co., 2018 WL
492693 (2d Cir. Jan. 22, 2018).
The coverage dispute arose out of a classaction suit against NASDAQ based on“technical failures” in executing the IPO for
Facebook, which resulted in the improper
processing of trade orders. The suit asserted
federal securities fraud claims and state law
negligence claims. The suit was ultimately
settled for $26.5 million. Beazley Insurance,
NASDAQ’s excess E&O insurer, paid its policy
limit of $15 million under an agreement inwhich NASDAQ assigned Beazley its rights
against Ace and Illinois National, NASDAQ’s
D&O insurers. Beazley sued the D&O insurers
seeking coverage for the settlement under
their policies. A New York federal district
court granted the D&O insurers’ summary
judgment motion, ruling that the underlying
claims were within the scope of a professional
services exclusion in the D&O policies. The
Second Circuit affirmed.
The exclusion provides that the insurer“shall not be liable for Loss on account of any
Claim . . . by or on behalf of a customer orclient . . . arising out of, or attributable to therendering or failure to render professional
services.” Beazley argued that the exclusion
does not apply because (1) the retail investors
who sued NASDAQ in the underlying classaction are not customers or clients, and(2) the underlying federal securities claims
are not based on the rendering or failure to
render professional services. The Second
Circuit rejected both assertions.
Although the policy does not define“customer,” the Second Circuit concluded
that the term unambiguously encompasses
NASDAQ’s retail investors, agreeing withthe district court’s reliance on “the customs,
practices, usages and terminology as generally
understood in the particular trade orbusiness” and noting that the “vast majority”

of federal courts have deemed retail investors
to be “customers” of a stock exchange. In
addition, the Second Circuit ruled that theunderlying securities claims arose out of therendering of professional services. Beazleyargued that NASDAQ’s alleged misstatements
and omissions in violation of federal
securities law were essentially advertising
activities and thus do not fall within the scopeof professional services. The court disagreed,
stating that “[t]he flaw in this argument isthat the [class action] plaintiffs could not
win at trial merely by showing that NASDAQ
made false and misleading statements
as to its capabilities. . . . The [underlying
complaint] recognizes this, and pleads losscausation based on failures in the technicalservice provided by NASDAQ.” As the court
explained, such alleged failures fall squarely
within the ambit of professional services.

Bad Faith Alert:

Mississippi Court Allows Bad Faith
Claim To Proceed Despite Dismissal
Of Breach Of Contract ClaimA Mississippi federal district court refused todismiss a bad faith claim against an insurer,
notwithstanding the dismissal of a breachof contract claim arising out of the sameunderlying conduct. Heritage Props., Inc.
v. Ironshore Specialty Ins. Co., 2018 WL
506483 (S.D. Miss. Jan. 22, 2018).
Heritage, a property management company,sought coverage for mold-related claims
under a general liability policy issued
by Ironshore. Ironshore assigned claim
administration to York Risk Services Group.
Several months later, Heritage learned
that a default judgment had been issued
against it. In response to inquiries made by
Heritage, York initially claimed that it had
sent a coverage denial several months earlier
by certified mail, and that the letter was
unclaimed and returned. York represented
that it then sent a second denial via regularmail. York later admitted that the disclaimer
had never been sent via certified mail.
Thereafter, Heritage sued Ironshore, Yorkand Ironshore’s underwriting company,
asserting breach of contract and bad faith,
among other claims.

6

The court dismissed the breach of contract
claim on the basis of an “organic pathogen”
exclusion, which provides that Ironshore has
no duty to defend Heritage against claims
arising out of harm attributable to “any typeof bacteria, virus, fungi, mold, mushroom,or mycotoxin.” The court reasoned that the
mold-related claims fall squarely within thescope of this exclusion and thus Ironshore
had no duty to defend the underlying suit.
The court declined to dismiss the breach of
the duty of good faith and fair dealing claim.
The court rejected Heritage’s assertion that
Ironshore breached the duty of good faithand fair dealing by failing to investigate theclaim, explaining that the duty to investigate
arises in first-party insurance cases but
not in third-party claims where the insurer
generally has no duty to investigate beyond
the allegations in the complaint. However,noting the uncertainty of whether Mississippi
law recognizes a bad faith claim based on
an insurer’s failure to provide a denial ofcoverage, the court found that the allegationsin the complaint sufficiently stated a plausible
bad faith claim based on York’s failure toprovide (and misrepresentations regarding) a
coverage denial.

Number Of
Occurrences Alert:
Applying “Triggering” Approach,West Virginia Court Rules That
Sexual And Physical Abuse Claims
Constitute Multiple Occurrences

A West Virginia federal district court ruledthat claims alleging sexual and physical abuse,malnourishment and educational neglect
constitute multiple occurrences. Brotherhood
Mutual Ins. Co. v. Bible Baptist Church, 2017
WL 6061979 (S.D.W.Va. Dec. 7, 2017).
Two students at a boarding school run by
the insured church filed separate complaints
alleging abuse, malnourishment andeducational neglect. Both complaints also
alleged that the church was negligent in its
hiring and supervision of the school staff.
Brotherhood Mutual, the church’s insurer,sought a declaration that the students’ claims
constitute one occurrence under the policy.
The court disagreed, ruling that the claims

constitute five separate occurrences underWest Virginia law.
The court applied a “triggering approach” that
focuses on “the event for which the insured
becomes liable, not some antecedent cause of
the injury,” in order to determine the numberof occurrences. The court reasoned that each
student’s sexual abuse claim constituted aseparate occurrence because the victim andalleged perpetrator were different in eachcase. The court further explained that theevents that triggered liability were the actsof each alleged perpetrator, rather than the
church’s negligent supervision. However, thecourt ruled that “each subsequent instance ofsexual abuse by one perpetrator against one
child falls under the same occurrence as thefirst instance of sexual abuse.” In so ruling,
the court relied on the policy’s definitionof “occurrence” (“an accident and includes
repeated exposure to similar conditions”)
as well as a separate policy provision statingthat multiple sexual acts will be considereda single act if undertaken by the same
perpetrator.
The court also held that the physical abuseclaims constitute a separate occurrence fromthe sexual abuse claims. The court reasoned
that the physical abuse claims did not ariseout of the same conditions as the sexual
abuse claims and were based on the alleged
conduct of a different staff member. However,unlike the sexual abuse claims, the court
determined that all physical abuse claims
comprise a single occurrence because liability
was triggered by a single source – the abusive
behavior of a single individual. Applying thesame reasoning, the court concluded thatthe malnutrition claims and the educational
neglect claims were separate occurrencesfrom the sexual and physical abuse claims,
but that all malnutrition claims were a single
occurrence (based on the alleged failure
to feed the students) and all educational
neglect claims were a single occurrence(based on the school’s implementation of an
improper curriculum).

7

Additional Insured Subrogation Alert:
Florida Court Rules That Insurer
Alert:
Implicitly Waived Equitable
Eleventh Circuit Rules That
Additional Insured Endorsement
Limits Coverage To Liability Caused
By Named Insured
Affirming a Georgia federal district court
decision, the Eleventh Circuit ruled that anadditional insured endorsement provides
coverage only when underlying liability wascaused in whole or in part by the named
insured. Employers Mutual Cas. Co. v.
Shivam Trading, Inc., 2018 WL 365216 (11thCir. Jan. 11, 2018).
Shivam leased a store from Sidhi Investment
Corporation. Both parties were sued ina slip-and-fall injury suit, but the claims
against Sidhi were dismissed on summary
judgment. Shivam sought additional insured
coverage under a policy issued to Sidhi. The
insurer denied coverage on the basis that theunderlying claims were outside the scope ofcoverage provided by the additional insured
endorsement. A Georgia district court agreed
and granted the insurer’s summary judgment
motion. The Eleventh Circuit affirmed.
The additional insured endorsement
provides coverage for parties listed asadditional insureds, “but only with respect
to liability . . . caused, in whole or in part, by
your acts or omissions . . . or in connection
with your premises owned by or rented toyou.” The parties disputed the meaning of“you” and “your” in the endorsement. Shivam
argued that those terms are ambiguous as
to whether they refer only to Sidhi as thenamed insured, or to Shivam (as an additional
insured as well). In contrast, the insurer
contended that “you” and “your” refer only
to the named insured, as expressly statedin the policy’s preamble. The court agreed
with the insurer, holding that the policy
unambiguously limits additional insured
coverage to liability caused in whole or inpart by Sidhi, the named insured. Because
Sidhi was found not liable for the underlying
personal injury, the court held that theinsurer had no duty to defend Shivam as anadditional insured.

Subrogation ClaimA Florida district court dismissed an equitable
subrogation claim brought by one insurer
against another, finding that the insurer
seeking contribution failed to establish
coverage under the other insurer’s policy,
and in any event, had waived its right to seek
such contribution. Privilege Underwriters
Reciprocal Exchange v. The HanoverInsurance Grp., 2018 WL 477277 (S.D. Fla.
Jan. 19, 2018).
The dispute arose out of a defamation suit
filed against Alan Dershowitz. During therelevant time frame, Dershowitz was insured
under a homeowner’s policy issued by
Privilege and a business owner’s policy issued
by Hanover. The defamation suit was settled,with both insurers contributing. Thereafter,
Privilege filed an equitable subrogation
claim against Hanover seeking to recover
the amount it contributed to the settlement.
Following a bench trial, the court concluded
that Privilege failed to prove Hanover’s
liability under its policy and that in any
event, Privilege waived its right to equitable
subrogation by volunteering settlement
payments without reserving its right to later
recover them.
The court held that Privilege’s equitable
subrogation claim required a thresholddemonstration that Hanover’s policy
provided coverage for the settled claims.
The court concluded that Privilege failed tomake such a showing because Hanover had
disputed coverage in a reservation of rights
to Dershowitz and its coverage obligations“still remain unresolved.” In any event,the court ruled that Privilege volunteered
settlement funds and waived its right to seek
equitable contribution. In so ruling, the court
noted that the insurers did not enter into asubrogation agreement and that Privilege
did not preserve a cause of action against
Hanover for indemnity, contribution or
subrogation. Further, the court emphasizedthat in its reservation of rights letter to
Dershowitz, Privilege cited only an intentional
acts exclusion and did not raise a priority-ofcoverage issue with respect to the Hanoverpolicy.

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

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This edition of the
Insurance Law Alert was
prepared by Bryce L. Friedman
bfriedman@stblaw.com /+1-212455-2235 and Susannah S. Geltman
sgeltman@stblaw.com /+1-212-4552762 with contributions
by Karen Cestarikcestari@stblaw.com.

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