Yoda, LLC v. National Union Fire Insurance
The Supreme Court, New York County, initially denied defendant National Union Fire's motion to dismiss the complaint and granted plaintiffs' cross motion for summary judgment, declaring the insurer’s disclaimer of coverage ineffective under Insurance Law § 3420 (d). The appellate court unanimously modified this order, denying the cross motion for summary judgment without prejudice to renewal after discovery, citing the lack of conducted discovery. However, the appellate court affirmed the denial of National Union’s motion to dismiss, noting lingering questions regarding the parties' intentions, the terms of the subcontract, and National Union’s delay in disclaiming coverage, which prevent a determination that Yoda and Riverhead were not additional insureds. Additionally, the employers’ liability exclusion in National Union's policy was found unavailing, as liability would be indirect if Yoda and Riverhead are determined to be additional insureds.