The Jewish Federation of Greater Washington, Inc. v. The Cincinnati Insurance Company

CourtDistrict Court, D. Maryland
DecidedMarch 28, 2025
Docket8:23-cv-01816
StatusUnknown

This text of The Jewish Federation of Greater Washington, Inc. v. The Cincinnati Insurance Company (The Jewish Federation of Greater Washington, Inc. v. The Cincinnati Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Jewish Federation of Greater Washington, Inc. v. The Cincinnati Insurance Company, (D. Md. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

THE JEWISH FEDERATION OF : GREATER WASHINGTON, INC. :

v. : Civil Action No. DKC 23-1816

: THE CINCINNATI INSURANCE COMPANY :

MEMORANDUM OPINION Presently pending and ready for resolution in this insurance coverage dispute are the motion for summary judgment filed by Plaintiff The Jewish Federation of Greater Washington, Inc. (“the Federation” or “Plaintiff”) (ECF No. 48), and the cross-motion for summary judgment filed by Defendant The Cincinnati Insurance Company (“CIC” or “Defendant”) (ECF No. 58). The issues have been briefed, and the court now rules, no hearing being deemed necessary. Local Rule 105.6. For the following reasons, both motions will be denied. I. Background A. Factual Background1 The Federation’s amended complaint asserts breach of contract and declaratory judgment claims against CIC, seeking indemnity and defense costs in connection with a claim made against it by ORT

1 Unless otherwise noted, the following facts are undisputed. America, Inc., and the Women’s American ORT Foundation (collectively “ORT”). The Federation is a non-profit charitable organization that

“serves various communities and other charitable organizations in the nation’s capital region, including the District of Columbia and Maryland.” (ECF No. 48 at 5). “One of the Federation’s functions is to manage and invest funds held for the benefit of other Washington, D.C.-area charitable organizations[,]” including ORT. (Id.). The Federation maintains insurance. One of the Federation’s policies was Policy Number EMN 044 97 53 (“CIC Policy”), a “claims made” policy issued by CIC for the period of August 15, 2017, to August 15, 2020. The CIC Policy includes three coverage sections: (1) General Provisions Applicable to All Liability Coverage (“General Provisions”), (2) Nonprofit Organization Directors and Officers Liability Coverage (“D&O”),

and (3) Employment Practice Coverage. (ECF No. 58-3). The Federation was also insured under Policy Number 8260-9776 (“Chubb Policy”), a “claims made” ForeFront Portfolio For Not-for- Profit Organizations Policy issued by Federal Insurance Company with a policy period of August 1, 2020, to August 1, 2021. The Chubb Policy contains four coverage sections: (1) Directors & Officers Liability and Entity Coverage Section, (2) Employment Practices Liability Coverage Section, (3) Fiduciary Liability Coverage Section, and (4) Crime Non-Liability Coverage Section. (ECF No. 48-7). In or about June and July 2020, the Federation fell victim to

a fraudulent scheme through which it caused four wire transfers, totaling $7,500,000, to be initiated from ORT’s funds to unauthorized third-party bank accounts in Hong Kong. On August 12, 2020, the Federation’s insurance agent emailed CIC saying, “Please find attached letters provided by the insured, as notice of wrongful acts (dated 6/10/20; 6/20/20; 7/10/20; 7/20/20); which may give rise to a management liability claim.” (ECF No. 48-8, at 2). Four of the attached letters were addressed to banks in China stating, “The Jewish Federation of Greater Washington would like to report a fraud perpetrated on our account at PNC Bank where each of your organizations played a role in that fraud.” (ECF No. 48-8, at 3-6). In each of the four letters,

Plaintiff listed the date in which the fraudulent transfer was initiated, the amount transferred, and the wire transfer bank details, including the account number and beneficiary address. (Id.). In the fifth letter, Plaintiff wrote to PNC Bank, as a follow up to an earlier phone call, reporting the fraudulent transfers. (Id. at 7). On August 13, 2020, Defendant acknowledged receipt of Plaintiff’s email, stating: The Cincinnati Insurance Company (“CIC”) has issued a Pillar Policy to The Jewish Federation of Greater Washington (JFGW). On behalf of CIC, I am in receipt of an e-mail from your insurance agent, Associated Insurance Management, to place CIC on notice of wrongful acts dated 6/10/2020, 6/20/2020, 7/10/2020, and 7/20/2020. Attached to this e- mail were five copies of correspondence which appeared to be directed to PNC Bank by JFGW in which JFGW advised PNC Bank of fraudulent wire transfers against their accounts at PNC Bank and requesting PNC Bank to report this fraud to certain Hong Kong banks that were the recipients of the fraudulent wire transfers.

. . . .

The information provided to CIC to date lacks notice of the specific “wrongful act”, the damages that may arise from a “wrongful act” and the circumstances by which the Insureds first became aware thereof, as such, CIC is unable to identify the nature and circumstances of the “wrongful act(s)” that the Insureds believe may give rise to a “claim”. In order for CIC to accept the Insured’s notice in this matter, please provide us with additional information or materials identifying the specific “wrongful act(s)” alleged against the Insureds, the injury or damage that may arise from the “wrongful act(s)” and the circumstances by which the Policy Insureds firm became aware of the “wrongful act(s)” that may give rise to a Claim under the Policy. Notice must be provided to CIC on or before the policy expiration date of August 15, 2020 – 12:01AM Eastern Standard Time.

(ECF No. 48-9 at 2-3).2 Plaintiff responded on August 21, 2020, with more details surrounding the fraud:

2 Plaintiff contends the August 13, 2020 letter “stated that the [Plaintiff’s] notice of wrongful acts was ‘lack[ing]’ but did The Federation’s understanding of what happened that led to the four fraudulent transfers has been rapidly evolving since the Federation first became aware that there had been a hack into its system on August 4 . . . . Upon review, it became clear that several prior log-ins had not been properly authorized. By the next day, August 5, the Federation had learned that the bad actor(s) had successfully infiltrated the system to defraud the Federation. As you will have seen from the five letters dispatched to PNC and the four receiving banks in Hong Kong, the Federation took prompt action to attempt to freeze the transfers, totaling as you saw $7,510,700, and alerted the FBI and other authorities. . . .

As for the possible wrongful act by the Federation staff, the investigation shows that the Federation CFO failed to follow proper protocols in responding to multi- authentication queries, on multiple occasions, after the bad actor(s) had obtained one or more passwords by unknown means. These deviations from the multi-authentication protocol allowed the bad actor(s) to access the Federation’s computer system multiple times and simulate requests for transfer of funds that appeared authentic. All four transfers were from accounts held for another charity organization for which the Federation manages endowment funds.

(ECF No. 48-12, at 16-17). Defendant responded on September 1, 2020, stating: In your August 21st correspondence you provide additional factual detail surrounding the fraudulent wire requests and indicated that the possible wrongful act of the [Federation] was “the investigation shows that the Federation CFO failed to follow proper

not provide any explanation of why the notice was purportedly insufficient.” (ECF No. 48-1 ¶ 31). protocols in responding to multi- authentication queries, on multiple occasions, after the bad actor(s) had obtained one or more passwords by unknown means. These deviations from the multi-authentication protocol allowed the bad actor(s) to access the Federation’s computer system multiple times and simulate requests for transfer of funds that appeared authentic. All four transfers were from accounts held for another charity organization for which the Federation manages endowment funds.

. . .

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The Jewish Federation of Greater Washington, Inc. v. The Cincinnati Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-jewish-federation-of-greater-washington-inc-v-the-cincinnati-mdd-2025.