[brief] As set forth in Plaintiffs’ initial brief, in the unlikely event the Court finds that [...] was properly unenrolled from the CCIP and [...] and [...] did not owe coverage, [...], as [...]’s insurance broker and fiduciary at the time it was enrolled, would be liable for that coverage as it negligently caused [...] to rely on [...]’s purported procurement of liability insurance.  In [...]’s Respondent’s Brief, [...] claims that [...] has no damages, and that [...] has no viable claim for damages.  [...] Db5-6.  To the contrary, [...] has expended a significant amount in litigating this ensuing coverage litigation, which arose from [...]’s negligence.  Further, although [...] contends that this coverage dispute is between the insurers, claiming it has “nothing to do” with that dispute and had “no control over whether [...] was enrolled in the CCIP,” [...] Db6, such blanket statements ignore [...]’s legal duty as an insurance broker.  Despite disagreeing with the conclusions of Plaintiffs’ expert, [...] can still be found negligent as a matter of law.  In its role as Program Administrator, [...] was responsible for ensuring that subcontractors were properly enrolled in the CCIP in order to work at the Project.  This role made [...] an insurance broker and fiduciary of each subcontractor that relied on [...]’s administration of the CCIP, which was mandatory for subcontractors to begin work.  Absent formal notice of cancellation, [...] was entitled to reasonably rely on the documentation it received from [...] confirming its enrollment and the coverage seemingly agreed upon.  See Aden v. Fortsh, 169 N.J. 64, 87 (2001) (“Insurance consumers who instruct their brokers to provide coverage are entitled to have those instructions followed without regard to the insured’s failure to detect the broker’s negligent conduct. ”); Rider v. Lynch, 42 N.J. 465, 482 (1964) (insureds “were entitled to rely upon and believe that the broker had fulfilled his undertaking to provide the coverage impliedly agreed upon, and that the policy sent to them represented accomplishment of that undertaking”).  As explained in greater detail in Plaintiffs’ initial brief, Pb43-47, expert testimony is not even necessary to prove [...]’s negligence as an insurance broker where it fell below the minimum standard of care for insurance brokers established by law.  Rider, 42 N.J. at 476; see also Indus. Dev. Assoc. v. F.T.P., Inc., 248 N.J. Super. 468, 471 (App. Div. 1991) (“Where a broker fails to meet the established minimum standards, expert testimony is not necessary to establish the culpability of the broker. ”); Dimarino v. Wishkin, 195 N.J. Super. 390, 394 (App. Div. 1984) (“the standard of care to be exercised by a broker in the circumstances, as noted above, has as a matter of law certain established minimums …  In the event of a failure to comply with these minimums, expert testimony is not necessary to establish the culpability of an insurance broker. ”).  If [...] was indeed wrongfully unenrolled from the CCIP, [...], as [...]’s insurance broker, would have failed to comply with the minimum standard of care established by law and would be liable for [...]’s costs as a matter of law.  **CONCLUSION**