37-Day Delay in Disclaiming Coverage Deemed Unreasonable

Bovis Lend Lease LMB, Inc. v. Royal Surplus Lines Ins. Co. (NY App., 1st Dept., Oct. 2, 2007)

Court holds that 37-day delay between insurer’s receipt of report from investigator detailing accident and its letter disclaiming coverage was unreasonable as a matter of law under NY Insurance Law § 3420(d), since the reasons for disclaimer were readily apparent from documents, including notice of claim and investigation report.
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