RD Am., LLC v. Farm Family Cas. Ins. Co.

2026 NY Slip Op 50243(U)
CourtNew York Supreme Court, Westchester County
DecidedMarch 3, 2026
DocketIndex No. 59114/2025
StatusUnpublished
AuthorGiacomo

This text of 2026 NY Slip Op 50243(U) (RD Am., LLC v. Farm Family Cas. Ins. Co.) is published on Counsel Stack Legal Research, covering New York Supreme Court, Westchester County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
RD Am., LLC v. Farm Family Cas. Ins. Co., 2026 NY Slip Op 50243(U) (N.Y. Super. Ct. 2026).

Opinion

RD Am., LLC v Farm Family Cas. Ins. Co. (2026 NY Slip Op 50243(U)) [*1]
RD Am., LLC v Farm Family Cas. Ins. Co.
2026 NY Slip Op 50243(U)
Decided on March 3, 2026
Supreme Court, Westchester County
Giacomo, 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This opinion is uncorrected and will not be published in the printed Official Reports.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 March 3, 2026
Supreme Court, Westchester County


RD America, LLC, Plaintiff,

against

Farm Family Casualty Insurance Company, Defendant.




Index No. 59114/2025

Attorney for Plaintiff:
Kennedys CMK LLP
Laura B. Dowgin, Esq.
22 Vanderbilt Avenue, Suite 2400
New York, NY 10017
(212) 252-0004

Attorney for Defendant
Chesney, Nicholas & Brower, LLP
Angela Patricia Pensabene, Esq.
485 Underhill Boulevard Suite 308,
Syosset, NY 11791
516-378-1700 William J. Giacomo, J.

Plaintiff RD America, LLC [FN1] moves for an order pursuant to CPLR 3212 and 3001 granting partial summary judgment and for a declaration that RD America is entitled to a defense from defendant Farm Family Casualty Insurance Company ("Farm Family") as an additional insured as a matter of law for the underlying action styled Rosalie Dellicarpini and Antonio Dellicarpini v JMDH Real Estate of Newburgh, LLC et al, pending in the Supreme Court, Bronx County, under Index No. 812027/2021E (the "Underlying Action or the Bronx Action") and declaring that RD America is entitled to reimbursement of costs paid in connection with the underlying action, plus interest.

Papers Considered                NYSCEF DOC NO. 8-18; 24-27
1. Notice of Motion/Statement of Material Facts/ Affirmation of Laura B. Dowgin, Esq./ [*2]Exhibits A-G
2. Affirmation in Opposition of Angela P. Pensabene, Esq./ Response to Statement of Material Facts
3. Reply Affirmation of Laura B. Dowgin, Esq./ Affidavit of Brian Emmert
FACTUAL AND RELEVANT PROCEDURAL BACKGROUND

RD America commenced this action by filing a summons and complaint on March 13, 2025. The complaint states that the declaratory judgment action arises from a personal injury action filed on September 3, 2021 under Index Number 812027/2021E in Bronx County. In the underlying action, that plaintiff alleged that she sustained personal injuries on February 23, 2021 when she slipped on ice and fell in a parking lot located at 1281 Route 300, Newburgh, NY. The premises was owned and operated by RD America. RD America then filed a third-party complaint against Farm Family's named insured, Foley Landscaping Contractors, Inc. (Foley).

The instant complaint alleges that RD America hired Foley to perform snow and ice removal services pursuant to a snow removal contract which was in effect on the date of the personal injury plaintiff's accident. The snow removal contract sets forth that Foley was to name "JRD Unico, Inc., its Subsidiaries and Affiliates, and the Subsidiaries and Affiliates thereof . . . as well as any companies or entities that the above companies, DBA's etc. are required to indemnify . . . as additional insured with respect to General Liability Coverage." According to RD America, the snow removal contract specifically obligates Foley to name RD America as an additional insured on its commercial general liability policy on a primary and noncontributory basis.

The complaint sets forth that Farm Family issued a commercial general liability policy to Foley during the relevant time period. The Policy includes the following additional insured endorsement:

"Schedule Name of Additional Insured Person(s) or Organization(s) JRD UNICO INC. AND ALL OTHERS PER WRITTEN CONTRACT 1281 Route 300 Newburgh, NY 12550-2957.
A. Section II — Who Is An Insured is amended to include as an additional insured the person(s) or organization(s) shown in the Schedule, but only with respect to liability for 'bodily injury', 'property damage' or 'personal and advertising injury' caused, in whole or in part, by: 1. Your acts or omissions; or 2. The acts or omissions of those acting on your behalf; in the performance of your ongoing operations for the additional insured(s) at the location(s) designated above."

The complaint asserts that the premises is included as a covered location in the additional insured endorsement. Further, the personal injury plaintiff's injuries were allegedly caused, at in least in part, by Foley's acts or omissions in its snow removal operations at RD America's premises.

The complaint states that since December 2021, RD America has been seeking a defense and indemnification from Farm Family as an additional insured. However, Farm Family has refused to defend RD America and RD America has been forced to defend itself.

The first cause of action seeks a declaratory judgment that RD America qualifies as an additional insured under the policy on a primary and non-contributory basis for the claims made in the underlying action. The second cause of action seeks a declaration that Farm Family is [*3]obligated to defend RD America in the underlying action on a primary and noncontributory basis. The third cause of action seeks a declaration that if Foley has any percentage of liability in the underlying action, Farm Family is obligated to completely indemnify RD America on a primary and noncontributory basis. The fourth cause of action is grounded in breach of contract and alleges that Farm Family has wrongfully failed to provide RD America with a defense for the claims made in the underlying action.


Instant Motion

RD America now moves, pursuant to CPLR 3212 and 3001, granting RD America partial summary judgment as to counts two and four of the complaint and declaring that RD America is entitled to a defense from Farm Family as a matter of law. RD America is also seeking to be reimbursed for costs paid in connection with the underlying action, plus interest.

Given what was alleged in the complaint and the supporting documents, RD America argues that it is entitled to a defense from Farm Family as an additional insured with respect to the underlying action. RD America subcontracted its snow removal services out to Foley. In the snow removal contract, Foley agreed to name RD America as an additional insured. Farm Family issued an insurance policy to Foley including JRD Unico and its subsidiaries, including RD America, as an additional insured and agreed to include them as an additional insured with respect to liability caused by Foley's acts or omissions. According to RD America, the allegations in the underlying complaint that plaintiff suffered injuries after slipping on snow/ice at a premises owned by RD America are sufficient to trigger Farm Family's duty to defend. RD America also alleges in the third-party complaint that Foley's actions with respect to snow removal were negligent.

RD America is also seeking to be reimbursed for costs already paid in connection with the underlying action from the date of tender, which is December 29, 2021, through the date of this order, plus interest. RD America states that it has incurred costs in excess of $50,000 in its defense for the underlying action.

In opposition, Farm Family argues that RD America has not established its right to coverage as an additional insured.

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Related

RD Am., LLC v. Farm Family Cas. Ins. Co.
2026 NY Slip Op 50243(U) (New York Supreme Court, Westchester County, 2026)

Cite This Page — Counsel Stack

Bluebook (online)
2026 NY Slip Op 50243(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/rd-am-llc-v-farm-family-cas-ins-co-nysupctwster-2026.