The United States Court of Appeals for the Second Circuit vacated orders entered granting Republic Insurance Company summary judgment interpreting facultative reinsurance certificates, finding that the provisions regarding when definitive statement of loss were required to be submitted were ambiguous, requiring consideration of extrinsic evidence and resolution of the ambiguity by a trier of fact. Folksamerica Reinsurance Co. v. Republic Ins. Co., Case No. 04-2716 (May 26, 2006).
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