Bucon, Inc. v. Pennsylvania Mfg. Assn. Ins. Co

In Bucon, Inc. v. Pennsylvania Mfg. Assn. Ins. Co. (151 AD2d 207) the insurer had issued a certificate which named the claimant for coverage as an additional insured. That certificate, as here, stated that it was issued for information only and did not "amend, extend or otherwise alter the terms and conditions of insurance coverage contained in the policy" (at 210-211). The Appellate Division, Third Department (Levine, J.), held that "this caveat could only have been reasonably interpreted by [the coverage claimant] as referring to terms and conditions of the coverage actually provided ... under the policy and any exclusions from such actual coverage, not a warning that an examination of the policy would negate the existence of any coverage for [the claimed additional insured], the very fact certified to by the insurer" (Bucon, Inc. v. Pennsylvania Mfg. Assn. Ins. Co., supra, at 211).