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AUTHORIZATION TO FORCE FEED INMATE FOR THE DURATION OF HIS INCARCERATION PROPERLY GRANTED.

The Third Department affirmed the grant of a petition by the prison warden authorizing the force feeding of an inmate for the duration of his incarceration:

When an inmate commences a hunger strike, which, if continued, would create a substantial risk of imminent death or serious permanent injury, a force-feeding order is warranted if the state’s intervention, even if contrary to the inmate’s constitutional rights, is reasonably related to its legitimate penological interests, including those in preserving the inmate’s life and maintaining safety and discipline within the facility (see Matter of Bezio v Dorsey, 21 NY3d 93, 99, 101-107 [2013]). The record shows that respondent had repeatedly engaged in hunger strikes since May 2013 with the stated purpose of obtaining a transfer to a maximum A security facility, and that respondent had stated that he would continue his hunger strike until he died or was transferred. …

We look no further than the holding in Matter of Bezio v Dorsey (supra) to reach the conclusion that the state’s interest in preserving respondent’s life outweighs any claimed infringement of respondent’s constitutional rights. On the record before us, Supreme Court properly issued a force-feeding order for the duration of respondent’s incarceration. Matter of Martuscello v Jua TT., 2016 NY Slip Op 08905, 3rd Dept 12-29-16

 

INVOLUNTARY MEDICAL TREATMENT AND FEEDING (INMATES) (AUTHORIZATION TO FORCE FEED INMATE FOR THE DURATION OF HIS INCARCERATION PROPERLY GRANTED)/INMATES (INVOLUNTARY MEDICAL TREATMENT AND FEEDING, AUTHORIZATION TO FORCE FEED INMATE FOR THE DURATION OF HIS INCARCERATION PROPERLY GRANTED)

DENIAL OF FREEDOM OF INFORMATION LAW REQUESTS REVERSED, CASE REMITTED TO DETERMINE IF REDACTION CAN ADEQUATLEY PROTECT PRIVACY.

The Third Department, reversing Supreme Court, determined that the requests for information about former public employees who applied for positions in state college police departments should not have been denied. The argument that redaction of identifying information from the documents (to which petitioner agreed) would not protect the applicants’ privacy was rejected. The matter was remitted for court review of the documents:

… [R]espondents argue — and Supreme Court agreed — that, given the prominent nature of the positions and the limited number of applicants, disclosure of the requested documents, even with appropriate redactions, could lead to the identification of the unsuccessful applicants. Such speculation, however, “does not rise to the level of ‘a particularized and specific justification for denying access’ to the [entirety of] the records requested” … . Respondents have failed to demonstrate any factual basis for their assertion that the requested documents cannot be redacted in such a manner as to protect the identity of the individual applicants … . …

… [T]he matter must be remitted to Supreme Court for an in camera inspection of the requested documents to determine the extent to which they contain information exempt from disclosure and whether such information can be redacted while still protecting the personal privacy of those individuals … . Matter of Police Benevolent Assn. of N.Y. State, Inc. v State of New York, 2016 NY Slip Op 08918 3rd Dept 12-29-16

 

FREEDOM OF INFORMATION LAW (FOIL) (DENIAL OF FREEDOM OF INFORMATION LAW REQUESTS REVERSED, CASE REMITTED TO DETERMINE IF REDACTION CAN ADEQUATLEY PROTECT PRIVACY)

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TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA.

The Third Department, reversing defendant’s conviction, determined the motion to suppress drugs seized from defendant’s car should have been granted. The deputy stopped defendant’s car based solely on a temporary inspection sticker without any suspicion of criminal behavior. The court noted that the denial of the suppression motion was appealable because defendant did not waive his right to appeal, and the harmless error standard applied because defendant pled guilty after the motion was denied:

The deputy candidly admitted that he had no idea whether the sticker was valid when he made the stop, nor did he indicate that the temporary sticker gave him any other reason for suspicion. He instead stated that his “general practice” was to stop any vehicle he encountered with a temporary inspection sticker in order to “ensure [that the sticker had] not expired.” It is entirely proper to operate a motor vehicle with a temporary inspection sticker under certain circumstances and, as a result, the display of one does not constitute grounds for a traffic stop absent a “specific articulable basis” to believe that illegality is afoot … . The practice of stopping any vehicle with a temporary inspection sticker, without more, represents impermissible “idle curiosity” as to the sticker’s validity rather than the “reasonable suspicion” of illegality needed to effect a traffic stop … . People v Driscoll, 2016 NY Slip Op 08902, 3rd Dept 12-29-16

CRIMINAL LAW (TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/SUPPRESS, MOTION TO (TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/STREET STOPS (TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/SEARCH AND SEIZURE (TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/APPEALS (CRIMINAL, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)/EVIDENCE (CRIMINAL LAW, TEMPORARY INSPECTION STICKER NOT SUFFICIENT TO JUSTIFY TRAFFIC STOP, DRUGS SEIZED FROM DEFENDANT’S CAR SHOULD HAVE BEEN SUPPRESSED, HARMLESS ERROR STANDARD APPLIES TO APPEALS AFTER A GUILTY PLEA)

MOTHER’S PETITION TO MODIFY VISITATION WITH HER DAUGHTER SHOULD HAVE BEEN GRANTED, MOTHER WAS SUCCESSFULLY CONTROLLING HER ADDICTION AND WAS MAINTAINING A FULL TIME JOB.

The Third Department, reversing Family Court, determined mother had sufficiently demonstrated a change in circumstances to warrant unsupervised visitation with her child. Mother was successfully controlling her addiction and was maintaining a full-time job:

“As the party seeking to modify a prior order of visitation, the [mother] bore the initial burden of showing that a change in circumstances has occurred since the entry thereof that is sufficient to warrant Family Court undertaking a best interests analysis in the first instance; assuming that requirement is met, the [mother] then must show that modification of the prior order is necessary in order to ensure the child’s continued best interests” … . In this regard, “expanded visitation is generally favorable absent proof that such visitation is inimical to the child[‘s] welfare” … .

The mother’s modification request stemmed from certain changes that had occurred in both her personal life and the child’s schedule since entry of the prior order. With respect to the child’s schedule, the mother explained that, now that the child was enrolled in school, there was a narrow window of opportunity during the school week (60 to 90 minutes each day) when she could enjoy visitations with her daughter. As to her personal life, the mother testified — without contradiction — that she had completed a detox program, was actively engaged in both group therapy and a community-based support group (Alcoholics Anonymous), the latter of which she attended three or four times each week, had obtained a sponsor (with whom she spoke daily and tried to meet in person twice a month), was participating in a Suboxone treatment program (for which she underwent regular testing to monitor the level of Suboxone in her system), was subject to regular drug testing for illegal substances (all of which came back negative), was successfully maintaining a full-time job and, as of the date of the hearing, had been “clean” for more than one year … . Matter of Beeken v Fredenburg, 2016 NY Slip Op 08919, 3rd Dept 12-29-16

 

FAMILY LAW (MOTHER’S PETITION TO MODIFY VISITATION WITH HER DAUGHTER SHOULD HAVE BEEN GRANTED, MOTHER WAS SUCCESSFULLY CONTROLLING HER ADDICTION AND WAS MAINTAINING A FULL TIME JOB)/VISITATION (FAMILY LAW, MOTHER’S PETITION TO MODIFY VISITATION WITH HER DAUGHTER SHOULD HAVE BEEN GRANTED, MOTHER WAS SUCCESSFULLY CONTROLLING HER ADDICTION AND WAS MAINTAINING A FULL TIME JOB)

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COMPLAINT INCLUDED ACTIONABLE DEFAMATORY STATEMENTS AGAINST THE INDIVIDUAL WHO MADE THE STATEMENTS IN A LETTER TO TOWN OFFICIALS, TOWN OFFICIALS ENTITLED TO ABSOLUTE OR QUALIFIED IMMUNITY.

The Third Department, partially reversing Supreme Court, determined several statements in this defamation action were not merely opinions and were therefore actionable against the defendant who made the statements in a letter to town officials. The republication of the defamatory statements as well as other statements by town officials were entitled to either absolute privilege or qualified immunity.  The decision includes substantive discussions of the elements of defamation, opinion versus fact, mixed opinion and fact, absolute immunity and qualified immunity, which cannot be fairly summarized here. With regard to (actionable) fact versus (nonactionable) opinion, the court explained:

It is well settled that, “[s]ince falsity is a necessary element of a defamation cause of action and only facts are capable of being proven false, only statements alleging facts can properly be the subject of a defamation action” … . “Distinguishing actionable fact from a protected expression of opinion is a question of law in which several factors are weighed, including whether the allegedly defamatory words have a precise meaning that is readily understood, whether the statement can be proven as true or false, and whether the context and surrounding circumstances would indicate that the comment is an opinion” … .

While a pure expression of opinion is not actionable, a “mixed opinion” — i.e., one that “‘implies that it is based upon facts which justify the opinion but are unknown to those reading or hearing it'” — can be the subject of a defamation claim … . “Rather than sifting through a communication for the purpose of isolating and identifying assertions of fact,” we must “look to the over-all context in which the assertions were made and determine on that basis whether the reasonable reader would have believed that the challenged statements were conveying facts about the plaintiff” … . Hull v Town of Prattsville, 2016 NY Slip Op 08917, 3rd Dept 12-29-16

DEFAMATION (COMPLAINT INCLUDED ACTIONABLE DEFAMATORY STATEMENTS AGAINST THE INDIVIDUAL WHO MADE THE STATEMENTS IN A LETTER TO TOWN OFFICIALS, TOWN OFFICIALS ENTITLED TO ABSOLUTE OR QUALIFIED IMMUNITY)/MUNICIPAL LAW (DEFAMATION, COMPLAINT INCLUDED ACTIONABLE DEFAMATORY STATEMENTS AGAINST THE INDIVIDUAL WHO MADE THE STATEMENTS IN A LETTER TO TOWN OFFICIALS, TOWN OFFICIALS ENTITLED TO ABSOLUTE OR QUALIFIED IMMUNITY)/PRIVILEGE (DEFAMATION, TOWN OFFICIALS, COMPLAINT INCLUDED ACTIONABLE DEFAMATORY STATEMENTS AGAINST THE INDIVIDUAL WHO MADE THE STATEMENTS IN A LETTER TO TOWN OFFICIALS, TOWN OFFICIALS ENTITLED TO ABSOLUTE OR QUALIFIED IMMUNITY)/IMMUNITY (DEFAMATION, TOWN OFFICIALS, COMPLAINT INCLUDED ACTIONABLE DEFAMATORY STATEMENTS AGAINST THE INDIVIDUAL WHO MADE THE STATEMENTS IN A LETTER TO TOWN OFFICIALS, TOWN OFFICIALS ENTITLED TO ABSOLUTE OR QUALIFIED IMMUNITY)

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DEFENDANT’S SUMMARY JUDGMENT MOTION WAS PREMATURE, PIERCING THE CORPORATE VEIL MIGHT BE AN ISSUE DETERMINING WHETHER WORKERS’ COMPENSATION IS THE SOLE REMEDY, FURTHER DISCOVERY NEEDED.

The Third Department determined defendant’s summary judgment motion in this wrongful death action should have been denied as premature. Plaintiff’s decedent was killed in a workplace accident and workers’ compensation death benefits were paid out. In addition to arguing that workers’ compensation was plaintiff’s sole remedy, defendant argued the corporation plaintiff sued had been dissolved and assets transferred to another corporation. Because piercing the corporate veil might be an issue, the Third Department held that plaintiff was entitled to discovery to flesh out the relationship among plaintiff’s decedent and the two corporations:

“[A] summary judgment motion is properly denied as premature when the nonmoving party has not been given reasonable time and opportunity to conduct disclosure relative to pertinent evidence that is within the exclusive knowledge of the movant or a codefendant” … . Although we have held that, “in certain situations, . . . more than one entity may be considered a plaintiff’s employer for purposes of workers’ compensation” … , defendant’s submissions fall far short of establishing that premise as a matter of law. A determination as to whether two entities are alter egos of each other requires a far more detailed record than is present here … . Pringle v AC Bodyworks & Sons, LLC, 2016 NY Slip Op 08924, 3rd Dept 12-29-16

CIVIL PROCEDURE (DEFENDANT’S SUMMARY JUDGMENT MOTION WAS PREMATURE, PIERCING THE CORPORATE VEIL MIGHT BE AN ISSUE, FURTHER DISCOVERY NEEDED)/CORPORATION LAW (DEFENDANT’S SUMMARY JUDGMENT MOTION WAS PREMATURE, PIERCING THE CORPORATE VEIL MIGHT BE AN ISSUE, FURTHER DISCOVERY NEEDED)/WORKERS’ COMPENSATION LAW (DEFENDANT’S SUMMARY JUDGMENT MOTION WAS PREMATURE, PIERCING THE CORPORATE VEIL MIGHT BE AN ISSUE TO DETERMINE WHETHER WORKERS’ COMPENSATION IS THE SOLE REMEDY, FURTHER DISCOVERY NEEDED)/NEGLIGENCE (DEFENDANT’S SUMMARY JUDGMENT MOTION WAS PREMATURE, PIERCING THE CORPORATE VEIL MIGHT BE AN ISSUE TO DETERMINE WHETHER WORKERS’ COMPENSATION IS THE SOLE REMEDY, FURTHER DISCOVERY NEEDED)/WRONGFUL DEATH (DEFENDANT’S SUMMARY JUDGMENT MOTION WAS PREMATURE, PIERCING THE CORPORATE VEIL MIGHT BE AN ISSUE TO DETERMINE WHETHER WORKERS’ COMPENSATION IS THE SOLE REMEDY, FURTHER DISCOVERY NEEDED)

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DEFENDANT’S STATEMENT DURING THE PLEA COLLOQUY THAT HE HAD NO MEMORY OF COMMITTING THE CRIME DUE TO DRUG USE REQUIRED FURTHER INQUIRY BY THE COURT, GUILTY PLEA SHOULD NOT HAVE BEEN ACCEPTED, NARROW EXCEPTION TO PRESERVATION REQUIREMENT APPLIED.

The Third Department determined defendant’s guilty plea to attempted robbery should not have been accepted by County Court. The error, although unpreserved, can properly be considered on appeal because defendant’s statement during the plea colloquy (that he had no recollection of committing the crime due to his drug use) raised the question whether he could have formed the intent to forcibly steal property:

Defendant’s sole contention is that his guilty plea was not knowing, voluntary and intelligent. Preliminarily, we note that, inasmuch as defendant failed to make an appropriate postallocution motion, this claim is unpreserved for our review … . Nevertheless, we find that the narrow exception to the preservation rule is applicable because defendant’s statement during the plea colloquy that he had no recollection of committing the crime due to drug use raises the unaddressed question of his ability to form the intent to forcibly steal property, an essential element of the crime of attempted robbery … . Under these circumstances, defendant’s statement “casts significant doubt upon [his] guilt or otherwise calls into question the voluntariness of the plea,” such that County Court was required to conduct a further inquiry to ensure that defendant’s guilty plea was knowing and voluntary … . People v Laflower, 2016 NY Slip Op 08899, 3rd Dept 12-29-16

CRIMINAL LAW (DEFENDANT’S STATEMENT DURING THE PLEA COLLOQUY THAT HE HAD NO MEMORY OF COMMITTING THE CRIME DUE TO DRUG USE REQUIRED FURTHER INQUIRY BY THE COURT, GUILTY PLEA SHOULD NOT HAVE BEEN ACCEPTED, NARROW EXCEPTION TO PRESERVATION REQUIREMENT APPLIED)/APPEALS (CRIMINAL LAW, DEFENDANT’S STATEMENT DURING THE PLEA COLLOQUY THAT HE HAD NO MEMORY OF COMMITTING THE CRIME DUE TO DRUG USE REQUIRED FURTHER INQUIRY BY THE COURT, GUILTY PLEA SHOULD NOT HAVE BEEN ACCEPTED, NARROW EXCEPTION TO PRESERVATION REQUIREMENT APPLIED)/GUILTY PLEAS (DEFENDANT’S STATEMENT DURING THE PLEA COLLOQUY THAT HE HAD NO MEMORY OF COMMITTING THE CRIME DUE TO DRUG USE REQUIRED FURTHER INQUIRY BY THE COURT, GUILTY PLEA SHOULD NOT HAVE BEEN ACCEPTED, NARROW EXCEPTION TO PRESERVATION REQUIREMENT APPLIED)

FOR CAUSE CHALLENGE SHOULD HAVE BEEN GRANTED, JUROR WAS A LONG-TERM FRIEND OF AN INVESTIGATOR WORKING ON DEFENDANT’S CASE.

The Third Department, reversing defendant’s conviction, determined defendant’s for cause challenge to a juror, who had been friends for 30 years with an investigator working on defendant’s case, should have been granted, despite the juror’s assurance he could be fair:

The juror’s mere status as a law enforcement officer, without more, would not necessarily have required his disqualification, nor would any relationship with a member of the District Attorney’s staff that was “little more than a nodding acquaintance” … . However, the juror described the investigator as a “friend,” and said that their social relationship had endured for more than 30 years and was sufficiently close to include the juror’s wife. While the juror did not specifically describe the recency or frequency of his contacts with this investigator, nothing in his description of their relationship suggested any recent lessening in the strength of this longstanding connection. Further, the investigator in question was working on defendant’s case, had already appeared in the courtroom by the time the juror was questioned and, according to the prosecutor, might continue to be present during the trial. People v Montford, 2016 NY Slip Op 08901, 3rd Dept 12-29-16

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DEFENDANT DID NOT DEMONSTRATE DOCUMENTS SOUGHT BY A DISCOVERY DEMAND WERE ENTITLED TO CONDITIONAL IMMUNITY AS DOCUMENTS PREPARED IN ANTICIPATION OF LITIGATION, MATTER REMITTED FOR COURT REVIEW OF THE DOCUMENTS.

In an action against a veterinary clinic stemming from an alleged attack by a dog in the waiting room, the Third Department determined the clinic did not demonstrate documents sought by plaintiff’s discovery demands were entitled to conditional immunity as documents prepared for litigation. The matter was remitted for court review of the documents:

Inasmuch as “[t]he purpose of liability insurance is the defense and settlement of claims . . . once an accident has arisen,” documents contained in the insurance adjuster’s file are generally protected by “a conditional immunity . . . as material prepared for litigation” … . Accident reports that are prepared with “a mixed purpose and result at least in part from the internal operations of the defendant’s business” are not, however, exempt from disclosure … . It is therefore incumbent upon “the party resisting disclosure to[, in the first instance,] show that the materials sought were prepared solely for litigation and this burden cannot be satisfied with wholly conclusory allegations” … . Hewitt v Palmer Veterinary Clinic, PC, 2016 NY Slip Op 08926, 3rd Dept 12-29-16

INSURANCE LAW (DEFENDANT DID NOT DEMONSTRATE DOCUMENTS SOUGHT BY A DISCOVERY DEMAND WERE ENTITLED TO CONDITIONAL IMMUNITY AS DOCUMENTS PREPARED IN ANTICIPATION OF LITIGATION, MATTER REMITTED FOR COURT REVIEW OF THE DOCUMENTS)/NEGLIGENCE (DEFENDANT DID NOT DEMONSTRATE DOCUMENTS SOUGHT BY A DISCOVERY DEMAND WERE ENTITLED TO CONDITIONAL IMMUNITY AS DOCUMENTS PREPARED IN ANTICIPATION OF LITIGATION, MATTER REMITTED FOR COURT REVIEW OF THE DOCUMENTS)/CIVIL PROCEDURE (DISCOVERY, CONDITIONAL IMMUNITY, DEFENDANT DID NOT DEMONSTRATE DOCUMENTS SOUGHT BY A DISCOVERY DEMAND WERE ENTITLED TO CONDITIONAL IMMUNITY AS DOCUMENTS PREPARED IN ANTICIPATION OF LITIGATION, MATTER REMITTED FOR COURT REVIEW OF THE DOCUMENTS)/CONDITIONAL IMMUNITY (DEFENDANT DID NOT DEMONSTRATE DOCUMENTS SOUGHT BY A DISCOVERY DEMAND WERE ENTITLED TO CONDITIONAL IMMUNITY AS DOCUMENTS PREPARED IN ANTICIPATION OF LITIGATION, MATTER REMITTED FOR COURT REVIEW OF THE DOCUMENTS)/PRIVILEGE (DEFENDANT DID NOT DEMONSTRATE DOCUMENTS SOUGHT BY A DISCOVERY DEMAND WERE ENTITLED TO CONDITIONAL IMMUNITY AS DOCUMENTS PREPARED IN ANTICIPATION OF LITIGATION, MATTER REMITTED FOR COURT REVIEW OF THE DOCUMENTS)/ACCIDENT REPORTS (DEFENDANT DID NOT DEMONSTRATE DOCUMENTS SOUGHT BY A DISCOVERY DEMAND WERE ENTITLED TO CONDITIONAL IMMUNITY AS DOCUMENTS PREPARED IN ANTICIPATION OF LITIGATION, MATTER REMITTED FOR COURT REVIEW OF THE DOCUMENTS)

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CRITERIA FOR DENIAL OF A MOTION FOR SUMMARY JUDGMENT AS PREMATURE ILLUSTRATED.

CIVIL PROCEDURE, INSURANCE LAW, CONTRACT LAW.

The Third Department determined defendant insurance company’s motion for summary judgment should have been denied as premature. Plaintiff was seeking reformation of the insurance contract to add plaintiff as an insured. Plaintiff held a mortgage on the insured property when the property was destroyed by fire:

Erie’s [the insurance company’s] motion for summary judgment should have been denied as premature. “[A] summary judgment motion is properly denied as premature when the nonmoving party has not been given reasonable time and opportunity to conduct disclosure relative to pertinent evidence that is within the exclusive knowledge of the movant or a codefendant” … . As is relevant to plaintiff’s claim, a party seeking reformation of a contract must establish, by clear and convincing evidence, either that the writing at issue was executed under mutual mistake or that there was a fraudulently induced unilateral mistake … .

The importance of documents and depositions that plaintiff sought but had not been provided is readily apparent. The premise of plaintiff’s cause of action is that, in executing the relevant insurance policy, the corporation and Erie both intended to include plaintiff as a loss payee but that, by mutual mistake, he was omitted. Erie had exclusive knowledge of its understanding of the intended coverage and any intended loss payees at the time of the execution of the relevant insurance policy. Moreover, it is likely to be in exclusive possession of any collateral documents memorializing the intended scope of the relevant insurance policy. Further, plaintiff’s contention that Erie has exclusive possession of employees and materials that could shed light on its intent as to the insurance policy is patently reasonable and not merely speculation … . Imrie v Ratto, 2016 NY Slip Op 08907, 3rd Dept 12-29-16

CIVIL PROCEDURE (CRITERIA FOR DENIAL OF A MOTION FOR SUMMARY JUDGMENT AS PREMATURE ILLUSTRATED)/SUMMARY JUDGMENT (CRITERIA FOR DENIAL OF A MOTION FOR SUMMARY JUDGMENT AS PREMATURE ILLUSTRATED)/INSURANCE LAW (REFORMATION OF POLICY, CRITERIA FOR DENIAL OF A MOTION FOR SUMMARY JUDGMENT AS PREMATURE ILLUSTRATED)/CONTRACT (REFORMATION, CRITERIA FOR DENIAL OF A MOTION FOR SUMMARY JUDGMENT AS PREMATURE ILLUSTRATED)/REFORMATION (INSURANCE POLICY, CRITERIA FOR DENIAL OF A MOTION FOR SUMMARY JUDGMENT AS PREMATURE ILLUSTRATED)

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