April 2010.  The Second Circuit agreed with the position advanced by Lewis Johs' client, the New York State Insurance Fund ("NYSIF"), in a dispute involving the applicability of New York Insurance Law Section 3420, and its requirement that an insurer issue a timely disclaimer of coverage in certain prescribed situations.  As a result of Lewis Johs' appellate victory, NYSIF recovered the one million dollar policy limit it had previously paid as a partial satisfaction of a bodily injury judgment.