Insurance Law Alert

January 2019

In This Issue
Second Circuit Rules That Warranty Nullified Excess Insurer’s Coverage
Obligation To Investment Firm
The Second Circuit ruled that Axis Insurance Company has no obligation to cover losses andexpenses arising out of a Securities and Exchange Commission investigation of Patriarch
Partners, LLC, finding that coverage was foreclosed by a warranty signed by Patriarch’s sole
director and officer. Patriarch Partners, LLC v. Axis Ins. Co., 2018 WL 6431024 (2d Cir. Dec.
6, 2018). (Click here for full article)“Renownedin the market as
accomplished trial
lawyers and coverageexperts who offer quality
representation to clients in
the insurance industry.”

Texas Supreme Court Rules That Joint Venture Provision Does Not Cap
Defense Costs In Deepwater Horizon Coverage Dispute
The Texas Supreme Court ruled that a Joint Venture Provision that limited coverage to twentyfive percent of excess policy limits did not encompass defense expenses, and Underwriters were
obligated to pay defense expenses up to the full policy limits. Anadarko Petroleum Corp. v.
Houston Casualty Co., 2019 WL 321921 (Tex. Jan. 25, 2019). (Click here for full article)– Chambers USA 2018

New York Court Rules That Insurers Must Defend Talent Agency In Suit
Brought By Hulk Hogan
A New York court ruled that a primary and umbrella insurer were obligated to defend a talentagency and an individual agent in a suit brought by wrestler Hulk Hogan that alleged breachof privacy and infliction of emotional distress. Zurich American Ins. Co. v. Don Buchwald &Assocs., Inc., 2018 NY Slip Op. 33325(U) (N.Y. Sup. Ct. New York Cnty. Dec. 21, 2018).
(Click here for full article)

In Asbestos Suit, Each Site Constitutes A Separate Occurrence And
Completed Operations Cap Applies, Says Pennsylvania Court
A Pennsylvania district court ruled that each site at which the policyholder installed or
removed asbestos-containing materials constituted a separate occurrence for policy coveragepurposes and completed operations limits apply. Ohio Valley Insulating Co., Inc. v. Maryland
Casualty Co., 2018 WL 6812527 (W.D. Pa. Dec. 27, 2018). (Click here for full article)

Reversing Lower Court, Fifth Circuit Rules That Multiple Collisions
Constitute A Single Accident For Policy Limit Purposes
The Fifth Circuit ruled that multiple car collisions constitute a single accident and that aninsurer was thus obligated to pay only a single policy limit. Evanston Ins. Co. v. Mid-Continent
Casualty Co., 2018 WL 6037507 (5th Cir. Nov. 19, 2018). (Click here for full article)

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Simpson Thacher & Bartlett LLP

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U.S. Supreme Court Rejects “Wholly Groundless” Exception To
Contractual Agreement To Arbitrate
The United States Supreme Court ruled that the threshold question of whether a dispute is
subject to arbitration is a matter for an arbitration panel, not a court, and that there is no“wholly groundless” exception to this rule. Schein, Inc. v. Archer & White Sales, Inc., 2019 WL
122164 (U.S. Jan. 8, 2019). (Click here for full article)

Vermont Supreme Court Rules That False Pretense Exclusion Does Not
Bar Coverage For Fraudulent Wire Transfer
The Vermont Supreme Court ruled that a False Pretense Exclusion was ambiguous and would
not be enforced to bar coverage for losses arising from a wire transfer initiated by a fraudulent
email. Rainforest Chocolate, LLC v. Sentinel Ins. Co., Ltd., 2018 WL 6817065 (Vt. Dec. 28,2018). (Click here for full article)

New York Court Erred In Dismissing Insured’s Consequential Damages
Claim, Says Appellate Court
Reversing a New York trial court decision, an appellate court held that a policyholder had
adequately pled a claim for consequential damages arising from the insurer’s alleged breach ofcontract and the duty of good faith and fair dealing. D.K. Property, Inc. v. National Union Fire
Ins. Co. of Pittsburgh, PA, 2019 WL 237454 (N.Y. App. Div. 1st Dep’t Jan. 17, 2019). (Click here
for full article)

Delaware Supreme Court Addresses Accrual Date For Statutory Bad
Faith Claim
The Delaware Supreme Court rejected a policyholder’s assertion that a statutory bad faithclaim does not accrue until a coverage determination is made, finding instead that accrual
occurs when the policyholder could have pled damages under the relevant statute. HomelandIns. Co. of N.Y. v. Corvel Corp., 2018 WL 6061261 (Del. Nov. 20, 2018). (Click here forfull article)

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Coverage Alerts:
Second Circuit Rules That Warranty
Nullified Excess Insurer’s Coverage
Obligation To Investment Firm
The Second Circuit ruled that Axis Insurance
Company has no obligation to cover losses
and expenses arising out of a Securities andExchange Commission (“SEC”) investigationof Patriarch Partners, LLC, finding thatcoverage was foreclosed by a warranty signed
by Patriarch’s sole director and officer.
Patriarch Partners, LLC v. Axis Ins. Co., 2018
WL 6431024 (2d Cir. Dec. 6, 2018).
The coverage dispute arose out of an SEC“informal inquiry” of Patriarch that began
in December 2009. Over the next few years,
the SEC changed its description of thematter to an “informal investigation” andrequested extensive information relating to
the company’s business practices. The SEC
also issued an internal order authorizing
subpoenas and indicating that the SEC
had information that tended to show that
Patriarch had acted in possible violation offederal securities law. Although Patriarch
maintained that it did not see a copy of thatorder until 2012, it conceded that its outside
counsel learned of it in June 2011.

Captioned Policy.” Lynn Tilton, the sole
director and officer of Patriarch, executed
the warranty.
In March 2015, the SEC filed anadministrative action against Patriarch.
Patriarch sought defense and indemnity from
Axis, which denied coverage on two bases:(1) that the SEC investigation was a “claim”
first made before the Axis policy inceptedand (2) that the warranty relieved Axis of its
obligations because the SEC investigation
constituted “facts and circumstances”
of which Patriarch was aware that could
reasonably have been expected to result ina claim.
A New York district court ruled in Axis’s
favor, finding that the SEC investigation
was a “claim” that was pending prior to
the policy’s inception and coverage wasthus barred by the “pending or prior claim”
endorsement. The Second Circuit affirmed on
different grounds. The Second Circuit heldthat coverage was foreclosed by the warranty
because, at the time of its execution, Patriarch
was aware of facts and circumstances thatwould reasonably be expected to result in acovered claim.
The Second Circuit rejected Patriarch’s
assertion that the warranty excluded coverage
only as to facts and circumstances of which
Tilton herself was personally aware, notingthat the warranty referred to “Patriarch”
rather than Tilton individually. Additionally,
the court rejected Patriarch’s contention thatthe warranty referred only to claims giving
rise to losses in excess of $20 million, theattachment point of the Axis policy.

Texas Supreme Court Rules That
Joint Venture Provision Does Not
Cap Defense Costs In Deepwater
Horizon Coverage Dispute
During this time frame, Patriarch maintained
a tower of insurance consisting of a primarypolicy plus two excess layers of coverage. In
August 2011, Patriarch’s broker recommended
that Patriarch purchase a third layer of excess
coverage and presented a quote from Axis.
The quote was contingent upon Patriarch’s
execution of a warranty representing that“neither the undersigned nor any otherdirector or officer of Patriarch is aware of any
facts or circumstances that would reasonably
be expected to result in a Claim under the

The Texas Supreme Court ruled that a Joint
Venture Provision that limited coverage totwenty-five percent of excess policy limits
did not encompass defense expenses,
and Underwriters were obligated to pay
defense expenses up to the full policy limits.
Anadarko Petroleum Corp. v. Houston
Casualty Co., 2019 WL 321921 (Tex. Jan.
25, 2019).
Anadarko, a minority-interest owner inthe Deepwater Horizon operation, sued3the Underwriters, seeking payment for
defense costs that Anadarko incurred incivil and government actions. The operative
policy included a Joint Venture Provisionthat provided:[A]s regards any liability of [Anadarko]
which is insured under this Section
III and which arises in any mannerwhatsoever out of the operation orexistence of any joint venture . . . theliability of Underwriters under thisSection III shall be limited to the
product of (a) the percentage interest of[Anadarko] in said Joint Venture and(b) the total limit afforded [Anadarko]
under this Section III.
Based on this provision, the Underwriters
paid Anadarko $37.5 million, representing
twenty-five percent of the $150 million
excess-coverage limit. Anadarko sought
additional payments, up to $150 million,
for defense expenses. The Underwriters
refused to pay, arguing that the Joint
Venture Provision capped all excess
coverage—including coverage for defense
costs—at twenty-five percent.
A Texas trial court granted Anadarko’s
summary judgment motion, finding thatthe endorsement applied to both liability
and defense obligations, but that a policy
exception, which increases coverage tofull policy limits when Anadarko is legally
liable for more than its proportionate sharein the joint venture, applied. An appellate
court reversed and rendered judgment for
the Underwriters. The appellate court heldthat the Joint Venture Provision limited
both defense and indemnity to twenty-five
percent of policy limits and that no exceptions
applied. The Texas Supreme Court reversed.
The Texas Supreme Court held that the Joint
Venture Provision limited the Underwriters’
liability only for amounts Anadarko was
required to pay in response to third-party
claims and did not encompass sums that
Anadarko paid as defense expenses. The courtemphasized that the policy “consistently
distinguishes between Anadarko’s ‘liabilities’and ‘expenses’” and that in other insurance
and legal contexts, the two categories of
payments are substantively distinct. The court
acknowledged that Anadarko’s liabilities
and defense expenses were both includedin the “Ultimate Net Loss” definition, but
concluded that the term “liability” in the Joint

Venture Provision referred only to liability fordamages imposed upon Anadarko by law, anddid not include defense expenses.

New York Court Rules That
Insurers Must Defend Talent
Agency In Suit Brought By Hulk
Hogan
A New York court ruled that a primary andumbrella insurer were obligated to defend atalent agency and an individual agent in a suitbrought by wrestler Hulk Hogan that alleged
breach of privacy and infliction of emotional
distress. Zurich American Ins. Co. v. Don
Buchwald & Assocs., Inc., 2018 NY Slip Op.
33325(U) (N.Y. Sup. Ct. New York Cnty. Dec.
21, 2018).
After compromising video and audio
recordings of Hogan were released to the
public, Hogan sued website Gawker andradio personality Michael Calta. The suitalso named as defendants Don Buchwald &Associates (“DBA”), the talent agency that
represented Calta, as well as Tony Burton,
Calta’s personal agent at DBA. The initial
complaint alleged breach of privacy andintentional infliction of emotional distressbased on an alleged conspiracy to publish
recordings that involved sexual and racist
content. An amended complaint added
negligence claims relating to DBA’s hiringand supervision of Burton. DBA’s primaryand umbrella insurers refused to defend on
several bases, including that the underlying
suit did not allege a covered occurrence. The
court disagreed and granted partial summary
judgment in DBA’s favor.
The primary insurer argued that theunderlying suit did not allege a covered“occurrence” because it alleged only
intentional conduct. The court rejected
this assertion, holding that even if Burton’s
conduct was intentional, the resulting
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damage may have been unexpected andunintended from the perspective of DBA, thepolicyholder. Further, the court explainedthat an intentional tort may be deemed“accidental” for coverage purposes if theelements of the tort can be established in theunderlying action without proving intentionalor knowing conduct. Here, because applicable
Florida law permits Hogan to establish
intentional infliction of emotional distressby demonstrating reckless conduct, the court
held that the claim triggered the potential forcoverage.
The court also ruled that the negligent
retention claim against DBA alleged an
occurrence even though the complaint
alleged that Burton intended to harm
Hogan. The court stated that in assessing
whether a negligent retention claim alleges
an occurrence, “the question for courts
to answer is not whether the employee
acted intentionally, but whether, from thestandpoint of the employer, the employee’s
acts were unexpected and unforeseen.”
As to the umbrella policy, the court ruledthat the underlying suit potentially triggeredcoverage under the “personal and advertising
injury” provision based on the invasionof privacy claim. The court rejected theinsurer’s assertion that such coverage wasunavailable because neither DBA nor Burton
published the audio or video recordings
themselves, noting that the policy contained
no such requirement.

Number Of
Occurrences
Alerts:In Asbestos Suit, Each Site
Constitutes A Separate Occurrence
And Completed Operations Cap
Applies, Says Pennsylvania Court
A Pennsylvania district court ruled thateach site at which the policyholder installed
or removed asbestos-containing materials
constituted a separate occurrence for policy
coverage purposes and completed operations
limits apply. Ohio Valley Insulating Co., Inc.
v. Maryland Casualty Co., 2018 WL 6812527(W.D. Pa. Dec. 27, 2018).
The court rejected the insurers’ assertion
that all underlying asbestos suits aroseout of a single occurrence—namely, thepolicyholder’s use of asbestos-containing
materials. Applying Pennsylvania’s causeoriented approach (and noting that the same
result would be reached under West Virginialaw), the court reasoned that each site was aseparate occurrence because claimants at eachsite were exposed to asbestos during the sametime and were “subjected to continuous orrepeated exposure to substantially the samegeneral condition.” The court distinguishedcases involving asbestos claims that arise
from “a single, negligent practice that could
be considered one cause such as distributing
a uniformly defective product from a single
manufacturer or selling a product containing
asbestos from one location.”
Addressing a separate issue, the court also
held that the policies’ aggregate limits
for “completed operations” applied. The
policyholder argued that the underlying
suits fell solely within “operations” coverage.
Rejecting this assertion, the court adopted
the reasoning set forth in In re Wallace &Gale Co., 385 F.3d 820 (4th Cir. 2004),
which found that “the completed-operations
hazard . . . encompasses any bodily injury
claim in which the claimant was injured byasbestos exposure attributable to an operationthat the insured completed prior to the startof the policy period.”

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Reversing Lower Court, Fifth
Circuit Rules That Multiple
Collisions Constitute A Single
Accident For Policy Limit Purposes
The Fifth Circuit ruled that multiple carcollisions constitute a single accident and thatan insurer was thus obligated to pay only asingle policy limit. Evanston Ins. Co. v. MidContinent Casualty Co., 2018 WL 6037507(5th Cir. Nov. 19, 2018).
Over a ten-minute period, a Mack truck
collided with several cars and objects,
resulting in severe injuries to and the death ofnumerous individuals. The parties settled all
claims and the sole remaining issue before thecourt was whether a series of three collisions
constituted a single accident or multiple
accidents for the purpose of determining thepolicy limits available. The record establishedthat the Mack truck hit a Honda Accord thatwas waiting in line at a toll plaza. After hitting
the Accord, the truck continued travelingthrough the toll lane for approximately 66 feet
before striking a Dodge Charger. The truck
pushed the Charger until it crashed into a
retaining wall, striking the toll booth in theprocess. The truck driver did not apply thebrakes at any time during the incident.
Applying Texas law, the district court ruledthat there were two separate accidents: thecollision with the Accord and the collision
with the Charger. The district court applied acause-oriented approach, but held that under
Texas law, an “overarching cause” of injuries(i.e., the Mack truck driver’s negligence) cannever constitute a single occurrence. Thus,
the district court looked to the “immediate
causes” of the injuries, and reasoned thatthe each incident giving rise to liability wascaused by a separate collision.
The Fifth Circuit reversed, finding only one
accident. The Fifth Circuit clarified that an“overarching cause” of injuries does not giverise to a single occurrence when it is not the“proximate, uninterrupted, and continuingcause of all the injuries.” For example,
Texas courts have rejected single-accident
arguments based on an “overarching cause”
of negligent supervision in sexual abusecases on the basis that “an overarching cause
should be ignored where an intervening
cause—like an intentional tort—breaks thechain of causation.” Here, however, the Fifth
Circuit concluded that the casual chain was

not broken by any intervening acts (such asa pause in conduct or an indication that thetruck driver had applied breaks or gained
control of his vehicle) and that the truck
driver’s ongoing negligence was the single,
proximate and uninterrupted cause of all
collisions.

Arbitration Alert:
U.S. Supreme Court Rejects“Wholly Groundless” Exception
To Contractual Agreement To
Arbitrate
The United States Supreme Court ruled thatthe threshold question of whether a disputeis subject to arbitration is a matter for an
arbitration panel, not a court, and that there
is no “wholly groundless” exception to thisrule. Schein, Inc. v. Archer & White Sales,
Inc., 2019 WL 122164 (U.S. Jan. 8, 2019).
In a contract dispute, Archer & White sued
Schein, seeking monetary damages andinjunctive relief. The contract required all
disputes to be resolved through arbitration,with the exception of those seeking injunctive
relief. When Schein moved to compel
arbitration, Archer & White argued that the
dispute was not subject to arbitration inlight of the demand for injunctive relief. The
central question was whether the gateway
issue of arbitrability should be decided bya court or an arbitration panel. The federal
district court ruled that where, as here, acourt finds that an argument for arbitration is“wholly groundless,” a court may resolve thethreshold question of arbitrability. The Fifth
Circuit affirmed.
The United States Supreme Court reversed,
finding the “wholly groundless” exception
6

inconsistent with the Federal Arbitration
Act (“FAA”) and case precedent. The Court
explained that the exception “confuses thequestion of who decides arbitrability withthe separate question of who prevails on
arbitrability.” The Supreme Court rejectedArcher & White’s assertion that the FAA
implicitly permits a “front end” judicial
review by allowing a “back end” judicial
review of arbitration awards and the scopeof an arbitration panel’s powers. The Court
remanded the matter for a determination ofwhether the contract at issue delegated thearbitrability question to an arbitrator, notingthat courts should not assume that parties
agreed to arbitrate arbitrability unless there isa “clear and unmistakable” intent to do so.

Computer Fraud
Alert:
Vermont Supreme Court Rules That
False Pretense Exclusion Does Not
Bar Coverage For Fraudulent Wire
Transfer
The Vermont Supreme Court ruled that a
False Pretense Exclusion was ambiguous andwould not be enforced to bar coverage forlosses arising from a wire transfer initiated bya fraudulent email. Rainforest Chocolate, LLC
v. Sentinel Ins. Co., Ltd., 2018 WL 6817065(Vt. Dec. 28, 2018).
A Rainforest employee received an email
purportedly from his manager. The email
directed him to wire approximately $20,000
to a specific bank account. After transferring
the funds, the employee discovered that theemail was fraudulent. Rainforest sought
coverage for its loss under a business-ownerpolicy. The insurer denied coverage, primarily
relying on a False Pretense Exclusion thatapplied to the “voluntary parting” withproperty if induced to do so by fraud or false
pretense. A Vermont trial court agreed withthis interpretation and granted the insurer’ssummary judgment motion. The Vermont
Supreme Court reversed, deeming theexclusion ambiguous.
The False Pretense Exclusion was precededby introductory language stating that theinsurer “will not pay for physical loss or
physical damage caused by or resulting from:

False Pretense.” The Vermont Supreme Court
held that this language was ambiguous as
to whether or not transferred funds were
“physical.” The court noted that the “policy
uses the two distinct phrases—‘physicalloss and physical damage’ and ‘loss
and damage’—within different sections
throughout the policy, sometimes switching
between the two sentence to sentence,”
without defining or explaining the difference
between the terms. The Vermont Supreme
Court interpreted the exclusion in Rainforest’sfavor, holding that the loss of transferredfunds was not physical in nature and thus that
the False Pretense Exclusion did not apply.
The Court remanded the matter for adetermination of whether the loss wasotherwise covered by “Forgery” or “Money or
Securities Theft” provisions. The court notedthat there could be no coverage under the“Computer Fraud” provision, which applied
only to “physical loss of or physical damage
to money . . . resulting from computer fraud,”
based on the court’s conclusion that the loss
was not physical.

Damages Alert:
New York Court Erred In
Dismissing Insured’s Consequential
Damages Claim, Says Appellate
Court
Reversing a New York trial court decision, an
appellate court held that a policyholder had
adequately pled a claim for consequential
damages arising from the insurer’s alleged
breach of contract and the duty of goodfaith and fair dealing. D.K. Property, Inc. v.
National Union Fire Ins. Co. of Pittsburgh,PA, 2019 WL 237454 (N.Y. App. Div. 1st Dep’t
Jan. 17, 2019).
A building owner sued its liability insurer,
alleging breach of contract and bad faith
based on the insurer’s intentional delay of
payment of a property damage claim. The
complaint alleged that the insurer made“unreasonable and increasingly burdensome
information demands throughout the threeyear period since the property damage
occurred” in order to “make the claim so
expensive to pursue that plaintiff would
abandon it altogether.” The owner sought
consequential damages that reflected7

engineering costs, painting, repairs,
monitoring and abatement costs and lossof rent, among other things. The trial court
dismissed the consequential damages
demand on the pleadings, and the appellate
court reversed.
Under New York law, a policyholder may seek
consequential damages resulting from aninsurer’s failure to provide coverage if suchdamages “were foreseen or should have been
foreseen when the contract was made.” Theappellate court held that foreseeability should
not be decided on a motion to dismiss because
at that stage, “the inquiry is not whether
plaintiff will be able to establish its claim,
but whether plaintiff has stated a claim.” Thecourt held that the policyholder adequately
pled a consequential damages claim because
the complaint alleged that the damages
were foreseeable based on the policyholder’scontractual obligation to “take all reasonable
steps to protect the covered property fromfurther damage.” In so ruling, the court notedthat there is no heightened pleading standard
for consequential damages.

Statute Of
Limitations Alert:
Delaware Supreme Court Addresses
Accrual Date For Statutory Bad
Faith Claim
The Delaware Supreme Court rejected apolicyholder’s assertion that a statutory bad
faith claim does not accrue until a coveragedetermination is made, finding instead that
accrual occurs when the policyholder could
have pled damages under the relevant statute.
Homeland Ins. Co. of N.Y. v. Corvel Corp.,
2018 WL 6061261 (Del. Nov. 20, 2018).
CorVel, a national Preferred Provider
Organization network operator, sued
Homeland Insurance, alleging statutory
bad faith pursuant to a Louisiana statutethat provides that an insurer that knowingly
misrepresents pertinent facts or policy
provisions shall be liable for damages
sustained by the insured. See La. R.S.
22:1973. The bad faith claim was based onHomeland’s alleged misrepresentations in
a declaratory judgment action filed against
CorVel. A Delaware superior court foundthat CorVel had established bad faithunder the relevant Louisiana statute andawarded it approximately $9 million indamages (the amount of CorVel’s underlying
settlement payment), together with $4.5
million in penalties. The Delaware Supreme
Court reversed.
The Delaware Supreme Court ruled that thebad faith claim was barred by the applicable
three-year statute of limitations under
Delaware law. The statute, 10 Del. C. § 8106,
requires a claim to be brought within three
years “from the accruing of the cause of suchaction.” The lower court held that the badfaith claim did not accrue until a court had
made a coverage determination, which waswithin the three-year period. Rejecting thisreasoning, the Delaware Supreme Court
concluded that CorVel could have pleddamages on the date upon which it settled
the underlying claims, which was nearly four
years before it alleged bad faith.

STB News Alerts:
In December 2018, Wolters Kluwer released
the Nineteenth Edition of the Handbook on
Insurance Coverage Disputes, co-authoredby retired Simpson Thacher partner and
now Justice Barry R. Ostrager and co-editedby Senior Counsel Elisa Alcabes and Karen
Cestari. The Handbook continues to be
one of the most comprehensive and citedreference works on insurance law. The newedition reports on numerous developments
and emerging issues across a variety of
substantive topics, including coverage issues
arising from cyber breaches, data loss andcomputer fraud.
Mary Beth Forshaw was profiled in “Notable
Women in Law” for 2019 by Crain’s
New York. The annual feature celebrates
exceptionally-talented female attorneys in
the New York City metropolitan area. The
honorees were nominated by their peers andchosen by the publication’s Editorial Board.
Lynn Neuner was selected by Euromoney’s
Benchmark Litigation as one of the “Top 100
Trial Lawyers in America.” The list highlights
elite trial attorneys in the U.S. selected basedon client and peer review.

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.

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

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

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

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

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

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

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

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

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

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

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

Daniel J. Stujenske+1-212-455-2419
dstujenske@stblaw.com

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

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

This edition of the
Insurance Law Alert was
prepared by Mary Beth Forshaw
mforshaw@stblaw.com /+1-212-4552846 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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