Insurance Coverage for Food Contamination and Recall...
Transcript of Insurance Coverage for Food Contamination and Recall...
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Presenting a live 90-minute webinar with interactive Q&A
Insurance Coverage for Food Contamination
and Recall Claims under CGL, Property
and Contamination Policies Navigating Scope of Coverage, Coverage Triggers, Relevant Exclusions and Policy Language Interpretation
Today’s faculty features:
1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific
TUESDAY, NOVEMBER 29, 2016
Robert D. Chesler, Shareholder, Anderson Kill, Newark, N.J.
Joann M. Lytle, Partner, McCarter & English, Philadelphia
Edward Rhone, Principal, Claims Manager, Parker Smith & Feek, Bellevue, Wash.
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Insurance Coverage for Food Contamination and Recall Claims
under CGL, Property and Contamination Policies
Edward Rhone
• There can be overlapping coverage between
CGL, Property, Stock Throughput and
Products Recall & Accidental Contamination.
• Each has specific triggers to consider.
• Each has “other insurance” language.
• Review of policy features to utilize.
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Practical Use of Policies
© 2016 Parker, Smith & Feek. All Rights Reserved.
• Based on facts of the event, each policy
should be reviewed for possible coverage
grants.
• Each should be evaluated for the least
impact to the policyholder – ie. Deductible,
Policy Limits for Protection, Broadest
coverage based on the facts of the event,
Other insurance provisions.
© 2016 Parker, Smith & Feek. All Rights Reserved. 7
Overlapping Coverage
• Coverage could include stock.
• Usually coverage is from an external cause.
• As previously discussed, pollution exclusion
likely.
• First party only.
© 2016 Parker, Smith & Feek. All Rights Reserved. 8
Property Coverage
• CGL may provide coverage for damage to a
3rd party in which the insured’s product is
incorporated – if it causes damage (property
damage and loss of use)
• Possible coverage for injury to 3rd parties.
• Check exclusions – specifically pollution
exclusion.
• Will not provide coverage for recall of the
insured’s product or work.
© 2016 Parker, Smith & Feek. All Rights Reserved. 9
Commercial General Liability
• The Marine Stock Throughput Insurance
Program is an all-inclusive Policy covering
goods from the time an Assured assumes an
interest in the goods until their interest
ceases.
© 2016 Parker, Smith & Feek. All Rights Reserved. 10
Cargo or STP
• “This insurance hereunder attaches from the time the
subject matter becomes at the Assured’s risk or the
Assured assumes interest and continues while the subject
matter is in Transit and / or in Store, on Exhibition or
elsewhere, including while held as Stock and / or at the
Assured’s Stores and / or Outlets and / or in Consolidation /
Deconsolidation Points and / or Processing. Assembly,
Renovation and Repair whether or not in the due course of
transit.”
• All transits and stock can be insured for a “Selling Price”
valuation under the STP. This accommodates any loss of
profit in respect of goods in the current supply chain.
© 2016 Parker, Smith & Feek. All Rights Reserved. 11
Definition of STP
• Policy can be “All Risk” as well as
manuscripted to include specific perils that
might affect the product, including change in
temperatures, accidental damage by specific
contaminates, etc.
• “Against all risks of physical loss or damage
to the subject-matter insured from any
external cause, including the risks of
spoilage and/or contamination.”
© 2016 Parker, Smith & Feek. All Rights Reserved. 12
Perils Covered by a STP
• Limitation – the STP may contain a “processing”
exclusion.
• May remove coverage for contamination that
occurs during production.
• First party only.
• Valuation can be written on a selling price basis.
• Each STP needs to be reviewed thoroughly for
limitations.
© 2016 Parker, Smith & Feek. All Rights Reserved. 13
Stock Throughput Policy
• Most RAC policies contain a “crisis” response
service.
• Requirement of the policy for the insured to use the
crisis hotline.
• Use is not subject to the policy’s SIR.
• But, “crisis response” is not “official” notice to the
insurer.
• Notice to insurer needs to follow the “notice
provision” of the policy – Likely first discovered and
reported within policy period.
© 2016 Parker, Smith & Feek. All Rights Reserved. 14
Recall & Accidental Contamination
• Provides first party coverage including:
– Recall Expenses
– Business Interruption Costs/Extra Expense
– Increased Cost of Working
– Rehabilitation Expenses
– Consultant Costs
– Adverse Publicity
• Usually contains coverage for malicious contamination/extortion.
• Policy can be endorsed for third party losses -
– Customer Loss of Profits (CLOP)
– Third Party Recall Liability (TPRL)
• Governmental Recall coverage.
• Product Refusal – think of it as “Collateral Damage” coverage.
© 2016 Parker, Smith & Feek. All Rights Reserved. 15
Recall and Accidental Contamination Policies
• Consider each policy and notice as required to
maximize insurance recovery.
• Example – Ammonia Escape at a third party facility
– Use of R&AC policy’s “crisis hot line” for expert
in dealing with the FDA and state authorities.
(not subject to the SIR)
– Use of STP for surveyors to also work with
regulators to agree to replacement of packaging
only – and for recovery of SIRs from the cold
storage facility.
© 2016 Parker, Smith & Feek. All Rights Reserved. 16
Practical Approach to Use of Policies Discussed
Thank You!
PRESENTER:
Ed Rhone
Parker, Smith & Feek
425-709-3735
www.psfinc.com
17 © 2016 Parker, Smith & Feek. All Rights Reserved.
Strafford November 29, 2016
1:00 p.m. – 2:30 p.m.
Insurance Coverage for Food
Contamination and Recall Claims
under CGL, Property and
Contamination Policies
Presenter:
Joann M. Lytle, Esq.
215-979-3878
Product Contamination Policy
Provides coverage for loss resulting from an Accidental
Product Contamination first discovered during the Policy
Period.
Can also provide coverage for publicity of an actual or alleged
Accidental Product Contamination.
Product Contamination Policies generally provide first-party
coverage.
Third-party coverage is available via endorsement or through
purchase of a separate recall policy.
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Product Contamination Policy (con’t)
Accidental Contamination:
Any accidental or unintentional contamination, impairment or
mislabeling of an Insured product(s), which occurs during or as a result
of its production, preparation, manufacture, packaging, or distribution;
provided that the use or consumption of such Insured product(s):
(i) has resulted in or would result in clearly identifiable
internal or external physical symptoms of bodily injury,
sickness, disease or death of any person(s) within one
hundred and twenty (120) days following such
consumption or use or
(ii) has caused or would cause physical damage to or
destruction of tangible property other than damage to
or destruction of Insured product(s).
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Product Contamination Policy (con’t)
Accidental Contamination:
Error in the manufacture, production, processing, preparation, assembly,
blending, mixing, compounding, packaging or labeling (including instructions for
use) of any Insured Products, or
The introduction into an Insured Product of an ingredient or component that is,
unknown to the Insured, contaminated or unfit for its intended purpose, or
Error by the Insured in the storage or distribution of any Insured Products whilst
in the care or custody of the Insured provided that the use or consumption of
such Insured Products has led to or would lead to:
i) bolding injury, sickness, disease or death of any person(s) or
animal(s) physically manifesting itself within 365 days of use
or consumption, or
ii) physical damage to or destruction of tangible property (other
than the Insured Products themselves.
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Loss Covered
Product Contamination Policies typically provide coverage for
the following categories of losses:
Pre-recall expenses, including chemical analysis of allegedly
contaminated product;
Recall costs
Business interruption
Rehabilitation Expenses Costs to re-establish the product to the projected level of sales or market share
Extortion costs Costs paid in response to a demand made under threat to commit malicious tampering
of a product
Consultants’ costs
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Loss Covered (cont.)
May provide coverage for expenses sustained by Named
Insured’s customer:
if Named Insured’s product becomes an ingredient or component in a
product manufactured, distributed, or handled by a customer of the
Named Insured
And the Named Insured is required to reimburse said customer
Insurer’s liability for customer’s expenses will not exceed the
expenses the Named Insured would have incurred in recalling
the customer’s products
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Coverage
Policyholder bears the burden of demonstrating:
An accidental or unintentional contamination, impairment or mislabeling
Of an Insured Product
Which occurs during production, preparation, manufacturing, etc.
Which has resulted or would result in bodily injury or clearly identifiable
internal or external physical symptoms of bodily injury.
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What Constitutes Contamination?
Depending on the specific language of the insuring agreement,
a recall based on the potential for contamination, without
evidence that an insured’s products were in fact contaminated,
may not be sufficient to constitute contamination under the
policies.
See, e.g., Ruiz Food Prods., Inc. v. Catlin Underwriting
U.S. Inc., No. 1:11-cv-00889, 2012 WL 4050001 (E.D. Cal.
Sept. 13, 2012); Little Lady Foods, Inc. v. Houston Cas. Co.,
819 F. Supp. 2d 759 (N.D. Ill. 2011).
25
What Constitutes an Error?
Some policies require an “error” on the part of the policyholder to
trigger coverage. In these cases, it is the policyholder’s conduct
during the “manufacture, processing, preparation, assembly,
blending, mixing, compounding, packaging or labeling” of the
product that a court considers.
In Fresh Express Inc. v. Beazley Syndicate, 199 Cal. App. 4th
1038 (Cal. Ct. App. 2011), the FDA issued an alert advising
consumers not to eat bagged, fresh spinach because of risks
associated with an E. coli breakout. This alert caused the
policyholder to voluntarily recall its bagged spinach. Court
determined recall was caused by FDA alert, not by policyholder
error and coverage was not triggered.
26
What Constitutes an Error? (con’t)
In Foster Poultry Farms, Inc. v. Certain Underwriters at Lloyd’s,
London, No. 1:14-cv-953, 2016 WL 235211, in contrast, the
Court agreed with the policyholder that there was an “error” as
required by the accidental contamination insuring agreement
where the policyholder “failed to maintain an adequate pest
control program and other sanitary controls.”
27
Preventative Recalls
As noted above, under the plain language of an accidental
contamination policy, a policyholder may not have coverage
for preventative recalls.
In these cases, courts find that the policy only provides
coverage for actual contamination – not losses associated
with the insured’s belief that a product may be contaminated.
See, e.g. Ruiz Food Prods., Inc. v. Catlin Underwriting U.S. Inc., No.
1:11-cv-00889, 2012 WL 4050001 (E.D. Cal. Sept. 13, 2012) (“The
Policy at issue, reasonably interpreted, does not cover losses incurred
to prevent contamination.”).
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Adverse Publicity
Food contamination and recall events can result in costly
adverse publicity
Chipotle’s recent E. coli outbreak impacted 14 states and 60 people –
this may seem relatively small given that there are nearly 2,000
Chipotle restaurants worldwide and some locations serve more than
300 customers an hour.
Sales declined 14.6% in the last quarter of 2015, and declined 30% in
December 2015 alone, representing an estimated $53 million in lost
sales.
Chipotle’s stock fell from a high of $754 a share in August 2015 to a low
of $404 in January 2016.
Chipotle incurred significant costs in an effort to get customers back into
restaurants, including increased and targeted marketing campaigns and
promotional offers for free or discounted food.
29
Adverse Publicity (con’t)
Accidental Contamination Policy may provide coverage for
losses resulting from “Publicity” implying accidental or
unintentional contamination.
Sample contamination policy defines “Publicity” as:
The reporting of an actual or alleged Accidental Product Contamination
during the Policy Period in local, regional, or national media
(including but not limited to radio, television, newspapers,
magazines or the Internet) or any governmental publication where
the Named Insured’s Product(s) and the Named Insured are
specifically named.
30
Adverse Publicity (con’t)
An insured may have coverage for adverse publicity even
where the insured’s product does not sustain actual
contamination if the publicity provision includes publicity
related to “an alleged” accidental product contamination.
See, e.g., Wornick Co. v. Houston Casualty Company, No. 1:11-cv-
00391, 2013 WL 1832671 (S.D. Ohio 2013) (denying insurer’s motion
for summary judgment regarding coverage for adverse publicity losses
where product was not contaminated but issues of fact remained as to
whether there was an adverse publication).
A product contamination policy may provide, as a part of
Loss, Rehabilitation Expenses, including:
Reasonable expenses necessarily incurred by the Named Insured to re-
establish the reputation and the market share of the product line which
has been the subject of an accidental product contamination.
31
Adverse Publicity (con’t)
Policyholder must check its contamination/recall policy’s
exclusions to determine whether coverage for adverse
publicity exists.
Some first-party recall policies contain exclusions for losses associated
with the adverse publicity that may arise after a food recall or
contamination event:
This insurance does not apply to any ‘loss’, cost or expense arising out of,
based upon, attributable to or involving directly or indirectly:
A. Any “adverse publicity”
32
Third Party Coverage
May be available by endorsement
Policyholder may want to purchase a separate recall policy for
third-party coverage.
Third-party recall insurance provides:
“[W]e shall reimburse you for product recall liability damages
resulting directly from a covered incident, provided (1) such
covered incident takes place in the coverage territory, and (2)
the initial oral or written publication of such covered incident
takes place during the policy period.”
33
A Covered Incident
“the recall, removal, recovery of possession or control,
withdrawal or disposal of, or purposeful destruction of your
product(s) from or by a distributor, purchaser, retailer,
wholesaler, or user of your product(s) solely because the use or
consumption thereof has resulted in bodily injury or property
damage, or because the use or consumption thereof poses
actual and imminent danger of resulting in bodily injury or
property damage.”
34
Product Recall Liability Damages
Covered third-party recall damages:
“Any sums that you become legally obligated to pay as
compensatory damages.”
Sums owed pursuant to contract of indemnity or contract of reimbursement
May include business interruption, loss of reputation, lost profits,
transportation and labor costs
Review policy – may not include liquidated or penalty damages
Defense costs
The recall policy may exclude coverage for costs incurred
to replace the recalled product – check policy
endorsements to determine coverage for these costs
35
Common Exclusions
Bodily Injury
Bars coverage for bodily injury, emotional distress or mental
anguish
Property Damage
Bars coverage for “physical injury to or destruction of tangible
property other than your product.”
36
Other Noteworthy Exclusions
There may be exclusions specific to products that are topical
or ingestible
Liability arising out of any pre-existing condition that insured knew of
or reasonably should have known of prior to inception of policy
Liability arising out of intentional acts or omissions that could
reasonably be expected to lead to a covered incident
37
Joann M. Lytle
Partner, Insurance Coverage Group
McCarter & English LLP
Joann Lytle helps corporate policyholders maximize their insurance
assets and has recovered hundreds of millions of dollars for a wide
range of companies, including those in the food services,
manufacturing and health care industries. She has handled
disputes involving commercial general liability, umbrella liability,
errors and omissions liability, directors and officers liability,
employment practices liability and cyber liability policies. In addition
to representing policyholders in coverage disputes, Joann also
provides insurance coverage advice and counseling to her clients
on an ongoing basis. She graduated maxima cum laude from
LaSalle University in 1987 and obtained her J.D., cum laude, from
Harvard Law School in 1990. Business Insurance Magazine
recognized Joann as one of its 2014 “Women to Watch.” In 2014,
she was recognized by Chambers USA as a “Leader in Their Field.”
Joann was selected as the exclusive Pennsylvania winner of the
Lexology Client Choice Award in 2013 and 2014. Joann has also
been recognized in Best Lawyers in America since 2008.
38
PRACTICE GROUP
Insurance Coverage
CONTACT Mellon Bank Center
1735 Market Street
Suite 700
Philadelphia, PA 19103-7501
215.979.3878
EDUCATION
Harvard Law School, J.D.,
cum laude, 1990
La Salle University, B.A., maxima
cum laude, 1987
BAR ADMISSIONS
Pennsylvania
New York
U.S. Court of Appeals, Third Circuit
U.S. District Court, Eastern District
of Pennsylvania
U.S. District Court, Middle District of
Pennsylvania
U.S. District Court, Southern District
of New York
Strafford Publications, Inc. Seminar
Live Webinar November 29, 2016 1:00 – 2:30 pm
Insurance Coverage for Food Contamination and Recall Claims under CGL, Property and Contamination Policies
Presenter:
Robert D. Chesler, Esq.
(973) 642-5864
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1075972v2 © 2016 Anderson Kill P.C. All Rights Reserved.
Disclaimer The views expressed by the participants in this program are not those of the participants’ employers, their clients, or any other organization. The opinions expressed do not constitute legal advice, or risk management advice. The views discussed are for educational purposes only, and provided only for use during this session.
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1075972v2 © 2016 Anderson Kill P.C. All Rights Reserved.
Speaker
Robert D. Chesler, Esq. Anderson Kill, P.C.
(973) 642-5864 [email protected]
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1075972v2 © 2016 Anderson Kill P.C. All Rights Reserved.
Peanut Corporation of America
Owner knowingly shipped salmonella tainted peanuts
9 deaths, 714 ill
360 companies and 3900 products affected
Owner sentenced to 28 years in prison
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1. NOTICE
Give notice early and broadly
Give notice of anything that even smells like it might be a claim
Late notice can be fatal!!!!
General liability (occurrence) vs. specialty policies (claims-made)
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2. Limits of liability
Are they high enough?
Damages are rising in food contamination cases
Are you sharing your policy with additional insureds?
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3. General Liability Policy: What is Covered?
Third party claims for:
– Bodily injury
– Property damage
– Personal and advertising injury (disparagement, copyright infringement, invasion of privacy, et al.)
– Does not cover economic loss
Unlimited duty to defend
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4. General liability policy vs. product contamination policy
Tangible damage vs. economic loss
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Occurrence
“Accident…neither expected nor intended from the standpoint of the insured.”
– Subjective standard
Naumes, Inc. v. Chubb Custom Ins. Co., 2007 U.S. Dist. Lexis 828634 (M.D. Pa. 2008)
– Coverage where insured accidentally mixed ingredient containing banned product into final product
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5. What is Property Damage? Glorybee and Sokol
– Sokol & Co. v. Atlantic Mutual Ins. Co., 430 F.3d 417 (7th Cir. 2005) — individually wrapped packages of peanut butter placed in cookie mix box
– Security Nat. Ins. Co. v. Glorybee, 2011 U.S. Dist. Lexis 27257 (D.Or. 2011) — peanuts incorporated into candy
– Shade Foods, Inc. v. Innovative Prod, Sales and Mktg., 93 Cal.Rptr. 2d (Ct.App. 2000) – splinters in cereal boxes
– Silgan Containers Corp. v. National Union, 2010 US. Dist. Lexis 30100 (N.D. Cal 2010) – Defective pull tabs
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Property Damage
Phibro, Inc. v. National Union Fire Ins. Co., 446 N.J. Super. 419 (App.Div. 2016). Additive that kept chickens from gaining weight caused property damage.
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Pollution Exclusion Original exclusion – limited to environmental pollution.
Now, much broader ‘absolute’ exclusions exist
See – Pepsico, Inc. v. Winterthur Int’l Amer. Ins. Co., 788 N.Y.S. 2d 142 (App. Div. 2004) – pollution exclusion did not apply to non-environmental pollution – faulty raw materials
Cincinnati Ins. Co. v. Becker Warehouse, Inc., 635 N.W. 2d 112 (Neb. 2001) – xylene fumes contaminated food in warehouse - excluded from coverage.
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Your Work/ Your Product Exclusions
Atlantic Mut. Ins. Co. v. Hillside Bottling Co., Inc., 903 A. 2d 513 (N.J. App. Div. 2006)
Bottler mixed ingredients into bottled beverages, resulting in ammonia contamination. Court found that bottled beverages were bottler’s product – no coverage.
See also, Nu-Pak, Inc. v. Wine Specialties Int’l, Ltd., 643 N.W. 2d 848 (Wis. Ct. App. 2002)
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Number of Occurrences Republic Underwriters Inc. Co. v. Moore, 493 F. Appr. 707 (10th
Cir. 2012) – Country Cottage prepared food in its facility
• People became sick at Country Cottage and at catered event
– Is there one occurrence for preparation of food? • Two occurrences for two places where people became sick? • Multiple occurrences – an occurrence for each person who became sick?
– Court found one occurrence, which minimized coverage for insured • Many courts nationally would have found either two or multiple occurrences.
– ‘Number of occurrences’ issue affects structure of insurance program re: deductibles, aggregate limits, and ‘batch clauses’
International Flavors & Fragrances, Inc. v. Royal Ins. Co., 844 N.Y.S. 2d 257 (App. Div. 2007) – 30 claimants alleging popcorn lung – 30 occurrences
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Property Insurance
PBM Nutritionals v. Lexington Ins. Co., 72 U.S.E.2d 707 (Va. Supreme. Ct. 2012)
– No coverage for product contamination
– Leaking valve sent contaminated water to infant formula ingredients
– No coverage — very broad pollution exclusion.
– Original policy would have provided coverage, but a total pollution exclusion added by endorsement negated it
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Property Insurance - Contamination
Leprino Foods Co. v. Factory Mut. Ins. Co., 453 F.3d 1281 (10th Cir. 2011): Contamination Exclusion — was there third party damage to trigger property damage coverage. – Contamination of cheese in warehouse
– Only covered if caused by 'other physical damage'
– Damaged fruit in warehouse contaminated cheese
See also, Allianz Ins. Co. v. RJR Nabisco Holding Corp., 96 F. Supp. 2d 253 (S.D.N.Y. 2000) – “peril not otherwise excluded” exception to exclusion.
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Direct Physical Loss or Damage S. Wallace Edwards & Sons, Inc. v. Cincinnati Ins. Co., 353
F.3d 367 (4th Cir 2003) – exposure to ammonia caused odor and color change
Gerawen Farming Partners, Inc. v. Westchester Surplus Lines Ins. Co., 2008 U.S. Dist. Lexis 4511 (E.D. Cal.2008) pitting of nectarines
Source Food Technology, Inc. v. United States Fidelity and Guaranty Co., 465 F. 3d 834 (8th Cir. 2006) – mad cow disease in Canada caused ban on beef imports; company couldn’t import beef tallow – no physical damage.
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Practice Pointers
Use an insurance broker who has expertise in food insurance.
Review your exposures
Cooperate with your insurance company, but protect your interests.
Do not take “CLAIM DENIED” as an answer from your insurance company.
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1075972v2 © 2016 Anderson Kill P.C. All Rights Reserved.
Thank You
Robert D. Chesler, Esq. Anderson Kill, P.C.
(973) 642-5864 [email protected]