In Fiore v. State Farm Fire & Cas. Co., 135 A.D.2d 602 [2d Dep't 1987], the homeowner's insurance policy provided that the "entire policy shall be void if any insured has intentionally concealed or misrepresented any material fact or circumstance relating to this insurance". The insurer claimed that the insured committed fraud in their claims for a burglary loss under the policy. The Appellate Division, Second Department affirmed an order granting the insureds' motion to strike the affirmative defenses of fraud as voiding the policy because, said the Appellate Division, unlike the provision in fire insurance policies that fraud voids the policies when committed "whether before or after a loss", the subject policy was ambiguous and was to be construed in the insureds' favor (135 A.D.2d at 603).