In West 16th Street Tenants Corp. v. Public Service. Mut. Ins. Co., 290 A.D.2d 278 (1st Dept. 2002) the court wrote (p. 279): "Plaintiffs delay in notifying defendant of the occurrence giving rise to the claim, the sole ground on which defendant disclaimed coverage, was obvious from the face of the notice of claim and the accompanying complaint, and defendant had no need to conduct an investigation before determining whether to disclaim." There the court held that the "30-day delay in disclaiming coverage was therefore unreasonable as a matter of law under Insurance Law $3420".