In AB Green Gansevoort v. Peter Scalamandre & Sons, Inc., 102 A.D. 3d 425, 426, 961 N.Y.S.2d 3 [1st Dept 2013]), at issue was an insurance policy that also provided that an organization is added as an additional insured under the policy "when you and such ... organization have agreed in writing in a contract or agreement that such ... organization be added as an additional insured on your policy." In interpreting this provision and applying it to the facts before the Court, the Court stated: It specifically provides that there must be a written agreement between the insured and the organization seeking coverage to add that organization as an additional insured. No such agreement exists here. Absent such an agreement, the plain terms of the policy have not been met and Green cannot seek coverage from Liberty as an additional insured. Although policies containing broader language have been found to allow for an agreement naming an additional insured without an express contract between the parties, the language at issue here is restricted to its plain meaning. (AB Green Gansevoort, 102 A.D. 3d at 426).