The court agreed with Travelers that Lloyd's had a duty to defend the underlying personal injury case. Travelers Indem. Co. v. Underwriters at Lloyd's, 2025 U.S. Dist. LEXIS 118445 (S.D. N. Y. June 23, 2025).

Jerome Avenue owned a multi-tenant property in the Bronx, New York. Jerome Avenue leased one of the units to Pawnit Jerome Corp. (Pawnit). Both Jerome Avenue and Pawnit were sued by Randolph Calosso, who alleged that he tripped and fell on the public sidewalk in front of the leased premises, sustaining serious injuries.

Travelers had issued a CGL policy to Jerome Avenue and provided a defense in the underlying case. The Travelers' policy included an "other insurance" provision, stating that coverage was "excess over any of the other insurance, whether primary excess, contingent or on any other basis, that is available to the insured when the insured is an additional insured . . ."