421 Kent Dev., LLC v. Prosight Syndicate 1110

2025 NY Slip Op 51369(U)
CourtNew York Supreme Court, Kings County
DecidedSeptember 1, 2025
DocketIndex No. 512588/2022
StatusUnpublished

This text of 2025 NY Slip Op 51369(U) (421 Kent Dev., LLC v. Prosight Syndicate 1110) is published on Counsel Stack Legal Research, covering New York Supreme Court, Kings County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
421 Kent Dev., LLC v. Prosight Syndicate 1110, 2025 NY Slip Op 51369(U) (N.Y. Super. Ct. 2025).

Opinion

421 Kent Dev., LLC v Prosight Syndicate 1110 (2025 NY Slip Op 51369(U)) [*1]

421 Kent Dev., LLC v Prosight Syndicate 1110
2025 NY Slip Op 51369(U)
Decided on September 1, 2025
Supreme Court, Kings County
Maslow, J.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and will not be published in the printed Official Reports.


Decided on September 1, 2025
Supreme Court, Kings County


421 Kent Development, LLC, WONDER WORKS CONSTRUCTION CORP
and CATLIN INSURANCE COMPANY, INC., Plaintiff,

against

Prosight Syndicate 1110, Defendant.




Index No. 512588/2022

Gallo Vitucci & Klar, LLP, Irvington (Jonathan W. Greisman of counsel), for plaintiffs.

O'Toole Scrivo, LLC, New York, NY (Amy E. Robinson of counsel), for defendant.
Aaron D. Maslow, J.

The following numbered papers were used on these motions: NYSCEF Document Numbers 3, 10-37, 47-75.

Upon the foregoing papers, the within motions are determined as follows.

Background


Introduction

The within action concerning insurance coverage derives from an underlying action ("Underlying Action") commenced by Robert Crutch against 421 Kent Development, LLC ("421 Kent") and Wonder Works Construction Corp. ("Wonder Works") (see NYSCEF Doc No. 14).[FN1] Crutch was injured on August 3, 2015, while employed by Metropolis HVAC Contractors, Inc. ("Metropolis") at 421 Kent Avenue, Brooklyn, New York ("the Premises"). Wonder Works managed the worksite and subcontracted with Centrifugal, Prosight Syndicate 1110's ("Prosight") insured, to install ductwork, pipe work, refrigerator lines, and the HVAC mechanical equipment at the Premises (see NYSCEF Doc No. 24). Centrifugal subcontracted to J&Z Mechanical/Construction Corp. ("J&Z"), and J&Z further subcontracted its work to [*2]Metropolis. The accident arose out of the work that Centrifugal was to perform, which included installing HVAC equipment at the Premises (see NYSCEF Doc No. 11 ¶ 20). This was the work that Crutch was hired to do (see id.). Wonder Works and 421 Kent filed a third-party claim against Centrifugal, J&Z, and Metropolis on September 29, 2016 (see NYSCEF Doc No. 3). Ultimately, on June 6, 2022, a jury verdict found Wonder Works solely liable for the accident in the Underlying Action (see NYSCEF Doc No. 43). All claims against third-party defendants Centrifugal, J&Z, and Metropolis were dismissed on March 6, 2023 (see NYSCEF Doc No. 64).

This action was commenced by 421 Kent, Wonder Works, and Catlin Insurance Company, Inc. ("Catlin") against Prosight.

Plaintiff Catlin issued a commercial general liability policy effective November 13, 2013, through December 15, 2016, to 421 Kent, with Wonder Works as a named insured ("Catlin Policy") (see NYSCEF Doc No. 31). The Catlin Policy contains a provision regarding other insurance, stating that the Catlin Policy insurance is excess if any other primary insurance is available to the named insureds covering liability for damages for which they have been added as an additional insured (see id. at PDF 27, ¶ 4 [b]).

Prosight issued a commercial general liability policy to Centrifugal effective October 15, 2014, through October 15, 2015 ("Prosight Policy") (see NYSCEF Doc No. 25). The Prosight Policy covered bodily injury and property damage liability and named as additional insured "Any person or organization for whom you are performing operations when you and such person or organization have agreed in writing in a contract or agreement that such person or organization be added as an additional insured on your policy" (NYSCEF Doc No. 25 at PDF 43). The subcontract agreement between Wonder Works and Centrifugal required Centrifugal to obtain and maintain a commercial general liability insurance policy and that the policy shall name as additional insureds, among other entities, 421 Kent and Wonder Works (see NYSCEF Doc No. 24 at PDF 72, ¶ 4).

Plaintiffs' counsel tendered four letters to Defendant Prosight with the obligations to defend and indemnify 421 Kent and Wonder Works against the Underlying Action as additional insureds under the Prosight Policy (see NYSCEF Doc Nos. 26, 27, 29, 30). Defendant Prosight acknowledged receipt of the second tender and informed Plaintiffs' counsel that it was investigating the matter (see NYSCEF Doc No. 28). Following that correspondence, Defendant did not respond to Plaintiffs' third and fourth tenders (see NYSCEF Doc No. 11, ¶¶ 37-38).

Plaintiffs move pursuant to CPLR 3212 for summary judgment against Defendant Prosight declaring that Defendant must reimburse Plaintiff Catlin for all defense costs in the Underlying Action from August 28, 2015.

Defendant Prosight cross-moves pursuant to CPLR 3212 for summary judgment declaring that it is not obligated to defend or reimburse Plaintiffs in the Underlying Action.



Plaintiffs' Position

Plaintiffs seek summary judgment pursuant to CPLR 3212, arguing that Plaintiffs 421 Kent and Wonder Works were additional insureds under the Prosight Policy, and Defendant's duty to defend was triggered when the Underlying Action was commenced and the allegations in the complaint gave rise to the reasonable possibility that Plaintiffs 421 Kent and Wonder Works might be liable for Crutch's injuries. Plaintiffs assert that Defendant Prosight must reimburse [*3]Plaintiff Catlin for all defense costs in the underlying action from August 28, 2015 to June 6, 2022, because it had a duty to defend its additional insureds Plaintiffs 421 Kent and Wonder Works (see id. at 12-14). Plaintiffs counter Defendant's laches defense by arguing that Defendant did not demonstrate that it was prejudiced by Plaintiffs' alleged delay in filing this action (see NYSCEF Doc No. 70 at 8). Plaintiffs counter Defendant's waiver argument by pointing to the tenders sent to Defendant where Plaintiffs 421 Kent and Wonder Works acted on their coverage rights, demonstrating that Plaintiffs did not voluntarily and intentionally relinquish their known contractual rights (see id. at 8-9).



Defendant's Position

Defendant seeks summary judgment arguing that an insurer can be relieved of its duty to defend if it establishes as a matter of law that there is no possible factual or legal basis on which it might eventually be obligated to indemnify its insured. Defendant argues that the jury's verdict finding Plaintiff Wonder Works solely liable for Crutch's accident extinguished Defendant's duty to defend or indemnify Wonder Works.

Additionally, Defendant argues that Plaintiffs should be barred from seeking relief on the grounds of laches, asserting that Plaintiffs' delay in bringing this suit caused prejudice. Defendant contends that if it has a duty to defend, it also has a right to control the defense for the Underlying Action, and because Plaintiffs filed this action on the "eve of the trial," Plaintiffs stripped Defendant of its opportunity to defend in the Underlying Action. Defendant argues that the timing of this action and the timing of Plaintiffs' motion for summary judgment were strategic moves on Plaintiffs' part and Plaintiffs are seeking retroactive recovery.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 NY Slip Op 51369(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/421-kent-dev-llc-v-prosight-syndicate-1110-nysupctkings-2025.