MEC&F Expert Engineers : A New Jersey appellate panel ruled that an insured’s settlement of an underlying action involving alleged defective installation of windows was reasonable and ordered the insurer to pay the amount of the settlement.

Saturday, June 27, 2015

A New Jersey appellate panel ruled that an insured’s settlement of an underlying action involving alleged defective installation of windows was reasonable and ordered the insurer to pay the amount of the settlement.


Why it matters: A New Jersey appellate panel ruled that an insured’s settlement of an underlying action involving alleged defective installation of windows was reasonable and ordered the insurer to pay the amount of the settlement. 

In this case, a condominium association sued Home Improvements by Randy (HIBR), a window installation company, after discovering water damage due to allegedly defective installation of windows in the association’s buildings. HIBR tendered the suit to three of its insurers that provided liability policies during the relevant time period. 

Two of the insurers provided a defense, but National Grange Mutual Insurance Company refused to participate. HIBR settled the underlying suit and assigned its rights in its insurance to the condo association, which then sued National Grange. 

A trial court ruled that National Grange was not required to pay the underlying settlement because the association had not demonstrated that the amount of the settlement was reasonable. But the appellate panel reversed, determining that the deal was reasonable. 

“In view of the probability of the association’s success and the size of the possible recovery at a potential trial, the association met its burden of showing that a reasonable factfinder could have found that a settlement for thirty percent of the damages that expert reports attributed to HIBR was reasonable,” the court said.





Detailed discussion: The Rockaway Condominium Association manages fourteen buildings and a clubhouse in an age-restricted residential condominium development in New Jersey known as Fox Hills. 

The first building was completed in 1999 and construction on the last building was completed in 2003. A few years later, an engineering company discovered substantial damage at Fox Hills resulting from continual exposure to moisture that had entered the buildings through defectively installed windows. The association filed suit against 77 entities alleging construction defects, product defects, and breach of contract.

One of the defendants was Home Improvements by Randy (HIBR), which was a subcontractor hired to install most of the windows at Fox Hills between April 2000 and March 2003. During the relevant time period, HIBR was covered by three insurance policies: one issued by Ohio Casualty Insurance Company, effective from 1995 through 2002; one issued by Zurich Insurance Company, effective from July 2003 through July 2004; and one (plus a separate umbrella policy) issued by National Grange Mutual Insurance Company, effective July 2003 through July 2007.

OCI and Zurich provided HIBR with a defense in the Fox Hills litigation, but National Grange denied coverage and refused to defend. Prior to trial in the underlying case, the parties stipulated that, between 1999 and 2007, water infiltrated each of the buildings and caused damage due to a variety of causes, including defectively installed windows. An engineering company provided a report attributing 30 percent of all water infiltration damage—or $4.5 million—to HIBR’s defective window installation.

HIBR eventually settled the claims against it for $1.9 million. Of this amount, HIBR settled its insurance claims against OCI and Zurich for $159,436 and $140,563, respectively. HIBR then assigned its claims for coverage of the remaining $1.6 million against National Grange to the Association.


The association then sued National Grange. At trial, the parties agreed to numerous stipulations, including the expert reports that attributed 30 percent of the damage to HIBR and the timeline for when the damage occurred.
National Grange moved to dismiss the association’s claims, arguing that the $1.6 million settlement amount was not reasonable in light of HIBR’s potential liability. 

National Grange also argued that HIBR’s settlement of its claims against OCI and Zurich for only $300,000 (combined) was unreasonable because the other two insurers paid far less than the amount being demanded from National Grange despite their having provided coverage for a longer period of time. The association countered that the expert reports showed that the water damage increased as time went on and peaked during National Grange’s coverage period. The trial court agreed with National Grange and granted its motion to dismiss.

The association appealed, and the appellate panel reversed, finding that the settlement was reasonable in amount and entered into in good faith, as required by New Jersey law. “The Association provided ample proof to determine the reasonableness of the HIBR settlement,” the court opined.

It was not contested that HIBR defectively installed windows at the development, causing substantial property damage, the court noted. While National Grange submitted no expert testimony on liability or damages, the association provided an expert report with “a spreadsheet detailing the exact amount of damages incurred by each injury to the property, the source of that damages amount if no invoice was available, and the parties responsible for each injury.” 

Examining the risk to the settling parties, the panel emphasized that expert testimony established HIBR was exposed to liability of up to $4.5 million. “The Association settled its claims against HIBR for $1.86 million, which amounts to approximately thirty percent of HIBR’s potential liability,” the panel wrote.


Moreover, the amount of the settlement that National Grange was required to assume was not unreasonable when compared to the settlement amounts of the other insurers, the court added, because the damage caused by HIBR’s defective installations manifested during 2005, within National Grange’s coverage period. “The damage did not manifest during the coverage periods of OCI or Zurich, and their liability exposure was consequently less” than National Grange, the panel opined.

“Given these proofs and [National Grange’s] refusal to settle or provide a defense, HIBR was bearing ‘the full burden of protecting its own interests’ at a trial with the Association,” the court said. 

“The extent of its liability was demonstrated by expert reports, ‘not mere allegations in the plaintiffs’ complaint.’ Although HIBR’s ‘actual liability’ was not fully established, more than the required potential liability was shown to exist here. In view of the probability of the Association’s success and the size of possible recovery at a potential trial, the Association has met its burden of showing that a reasonable factfinder could have found that a settlement for thirty percent of the damages that expert reports attributed to HIBR was reasonable.”

To read the decision in Fox Development Co. v. Praetorian Insurance Co., click here.


SUPERIOR COURT OF NEW JERSEY
APPELLATE DIVISION
DOCKET NO. A-0



FOX DEVELOPMENT CO., INC.,
GIANT ASSOCIATES, INC.,
MORTON SALKIND, CAROLE SALKIND,
STEPHEN SALKIND, and
JOHN HARRIS,

Plaintiffs,

v.

PRAETORIAN INSURANCE COMPANY,
f/k/a INSURANCE CORPORATION
OF HANOVER, SELECTIVE INSURANCE COMPANY
OF AMERICA, HARLEYSVILLE INSURANCE COMPANY,
SCOTTSDALE INSURANCE COMPANY,
QUINCY MUTUAL FIRE INSURANCE COMPANY,
OHIO CASUALTY COMPANY, CHARLES F. HEIDT,
INC., and JAMES E. GILMORE AGENCY, INC.,

Defendants,

and

OHIO CASUALTY INSURANCE COMPANY,

Third-Party Plaintiff,

v.

INTERSTATE FIRE AND CASUALTY COMPANY,
INDIAN HARBOR INSURANCE COMPANY,
COLONY NATIONAL INSURANCE COMPANY,
and ZURICH INSURANCE COMPANY,

Third-Party Defendants,

and

FOX HILLS AT ROCKAWAY CONDOMINIUM
ASSOCATION, INC.,

Plaintiff/Intervenor-Appellant/
Cross-Respondent,

and

NATIONAL GRANGE MUTUAL INSURANCE
COMPANY,

Third-Party Defendant-Respondent/
Cross-Appellant.
___________________________________________________
April 27, 2015

Argued February 23, 2015 – Decided

Before Judges Simonelli, Guadagno, and Leone.

On appeal from the Superior Court of New Jersey, Law Division, Morris County, Docket No. L-446-08.

James G. O'Donohue argued the cause for appellant/cross-respondent (Hill Wallack LLP, attorneys; Mr. O'Donohue and Susan L. Swatski, of counsel and on the brief; Lisa Chapland, on the brief).

Haydn J. Brill argued the cause for respondent/cross-appellant (Brill & Associates, P.C., attorneys; Mr. Brill, of counsel and on the briefs; Corey M. Reichardt, on the briefs).

PER CURIAM

Plaintiff-intervenor Fox Hills at Rockaway Condominium Association (Association) appeals from the order entered September 11, 2013 dismissing its complaint against third-party defendant National Grange Mutual Insurance Company (NGM). NGM cross-appeals from the trial court's findings that plaintiff-intervenor's settlement with another defendant, Randy Lee, trading as Home Improvements by Randy (HIBR), involved a business judgment and that coverage existed by estoppel. For the reasons that follow, we reverse and remand for a new trial.
I.
The Association manages the lands and buildings at the age-restricted residential condominium development known as Fox Hills at Rockaway. Fox Hills consists of fourteen buildings in the Township of Rockaway. Construction on the first building was completed in 1999 and the last was completed in 2003.
In March 2005, the Association was sued by its landscaper, Benkendorf Grounds Pro, Inc., for unpaid labor and services. During the pendency of the Benkendorf action, damage was discovered at Fox Hills when an engineering company, Flannery, Webb and Hansen, P.A. (FWH), conducted an inspection which revealed that substantial damage to the development had resulted from continual exposure to moisture that had entered the buildings through, among other places, defectively-installed windows.
After extensive litigation in the Benkendorf action, the Association filed an amended third-party complaint against seventy-seven entities alleging construction defects, product defects, breach of contract, mismanagement of the condominium property, fraud, and statutory and regulatory violations (the 2010 action).
HIBR was named as a defendant in the 2010 action. HIBR was hired by United Window and Door to install most of the windows at Fox Hills, which it did from April 2000 until March 2003.
During the relevant time period for the 2010 action, HIBR had three insurance policies: (1) an Ohio Casualty Insurance Company (OCI) policy effective July 10, 1995 through July 10, 2002; (2) a Zurich Insurance Company policy effective July 11, 2003 through July 11, 2004;1 and (3) an NGM policy effective July 12, 2003 through July 12, 2007. NGM provided a business owner's liability coverage policy and an umbrella policy.
OCI and Zurich provided HIBR with a defense in the 2010 action. NGM denied coverage for the claims, and refused to defend HIBR. During the litigation, OCI filed a third-party complaint against NGM for contribution.
Prior to trial, the parties stipulated that between 1999 and 2007, water infiltrated each of the fourteen buildings and the club house, and damage occurred to the interior elements at Fox Hills due to a variety of causes including the defectively-installed windows. In 2009, French Engineering, Inc. (FEI) provided the Association with a budget projection for remediating the water-induced damage at the development. FEI's report broke the damage into eight categories of moisture exposure, and then broke those categories into subparts specifying the type of damage caused by each kind of exposure. FEI attributed thirty percent of all water infiltration damages, or $4.5 million, to HIBR's defective window installation.2
Before trial began, two mediation sessions were held. Counsel for NGM attended the first session but left before negotiations concluded. No NGM representative appeared on the second day of mediation. While NGM claims that it "was excluded" from the discussions, it provides no support for this assertion. Indeed, the judge expressly found that NGM "was not willing . . . to work out that settlement."
Following mediation, HIBR and the Association entered into a settlement, effective September 12, 2011, resolving "any and all disputes and/or claims for damages between them" and assigning to the Association any and all claims that HIBR might have against NGM. HIBR agreed to a stipulated judgment for "$1,860,000 comprised of $1,360,000 in payment of the Association's claims for damage to its property . . . and $500,000 for repair and replacement costs of doors and windows[.]"
In a separate agreement, HIBR and the Association settled the property damage claims covered by the OCI and Zurich insurance policies. OCI agreed to pay $159,436.71, while Zurich paid $140,563.29 to the Association.
Noting the payment of $300,000 of the $1,860,000 stipulated settlement amount, the trial court entered a judgment in favor of the Association against HIBR in the amount of $1,560,000 on November 4, 2011. The order provided that HIBR would assign its claims against NGM to the Association.
In January 2012, NGM acknowledged receipt of the HIBR-Association settlement, and reiterated its denial of coverage "for any claims arising out of or in connection with execution of the Settlement Agreement and Release." On April 20, 2012, the Association filed an intervening complaint in OCI's third-party suit against NGM in order to seek declaratory relief for payment of the judgment, as well as consequential damages and attorneys' fees.
Trial between the Association and NGM began on June 18, 2013. The trial judge repeatedly encouraged the parties to reach factual stipulations in order to obviate the need for expert witness testimony. The court made several comments indicating its strong preference for trying the case without the need for expert testimony:
Well, of course, if you were totally sure of your position, then you could say I'll stipulate . . . and we don't need the expert.

. . . .

The question is do we need the [expert] guy from Texas.

. . . .

So the question is agreeing to that does that hurt your case? Well, think about it.

. . . .

See if we can work out a stipulation of facts so we can avoid the testimonial portion of it.

Counsel for the Association repeatedly insisted that he needed his expert's testimony to establish both the timeline of liability and amount of damages. The judge took a recess to allow both attorneys to contact their clients to attempt to reach factual stipulations. The court suggested that counsels' negotiations on the stipulations could be off the record. Following negotiations, the parties then entered into thirteen stipulations on the record:
[1] [F]rom 1999 to 2003, water infiltrated each of the 14 buildings and club house due to a variety of reasons; including windows, E.F.I.S., stucco, roofs, gutters, and stone; including in the years 1999 through 2007. The exact cause of any one particular leak on any particular date is undetermined. That's the first stipulation, Your Honor.

[2] Second, Warren French, that's [the Association's] expert, would testify that water infiltrated each of the Fox Hills buildings from the completion of construction [of the first building in 1999] through 2007 and damage occurred to the interior elements, including in 2003 to 2007 as a result of construction issues related to E.F.I.S., stucco, roof, gutters, and stone and the windows.

[3] Warren French would not be able to testify as to the precise cause or component at fault for any one particular leak which resulted in consequential damage to the common elements of the Association.

[4] Warren French's expert[] reports . . . attribute 30 percent of the water infiltration to the window installation or misinstallation. And attribute 30 percent of the consequential damages to window leaks, with the cost of repair at 4.5 million dollars.

[5] Warren French's testimony in this action would be consistent with those reports and would attribute 30 percent of the water infiltration to the window installation and attribute 30 percent of the consequential damages to window leaks, with a 4.5 million dollar cost to repair.

[6] The parties agree that the contents of th[ese] stipulation[s] are not intended to expand upon or enlarge the contents of any report or opinion issued by Warren French in the underlying litigation.

[7] In August 2005, F.W.H. . . . issued an engineering transition report for Fox Hills based upon non invasive investigation studies and inspections performed by F.W.H. on various dates, commencing in January of 2005.

[8] All reports concerning the cause and origin of water intrusion into the buildings of Fox Hills were delivered to the Association in or about August of 2005.

. . . .

[9] The work for which Randy Lee was hired by United Windows did not include flashing or integration with other building components, including the stucco or E.F.I.S. cladding.

[10] [The Association's] liability experts reports by F.W.H. opined that flashing installation is the responsibility of the window installer[.]

[11] Randy Lee had no contract or agreement with [the Association] or [the development company].

[12] Randy Lee's counsel in the [2010 action] retained experts who disputed the findings and opinions of FWH Associates and Warren French in whole or in part as set forth in those reports. And I should tell the Court we are going to mark the reports of both the Plaintiff's experts and Defendant's experts. And those are going to be submitted by stipulation.

[13] And then the last stipulation. None of the stipulation[s] by the parties are intended to concede an occurrence under the [NGM] policy issued to [HIBR] . . . [o]r any other policy.

Once the stipulations were placed on the record, the court stated, "Okay. So that means we don't need the live witness[es]. . . . What's next?" Counsel noted that they would also be stipulating about twenty documents into the record, which they would review over lunch and submit at the end of the day for overnight judicial consideration. Notably, the record does not identify what documents were stipulated into the record for the judge's consideration.
The Association then rested, and NGM moved for dismissal pursuant to Rule 4:37-2(b). NGM first argued that although its coverage for Randy Lee individually was in place during July 2003-04, the damage did not "manifest" until its discovery in March 2005, and NGM's subsequent policies were issued to Randy Lee's corporation, HIBR, which was not sued in the 2010 action. NGM also argued that the HIBR, OCI, and Zurich settlements were not reasonable, as those policies had limits of $500,000 per year for four years of total coverage, the Association settled those $2,000,000 claims for $300,000 total, and entered a $1.86 million judgment against HIBR to recover from NGM, who provided only one year of coverage.
The Association responded that its expert reports showed that the damages increased as time went on, peaking during the NGM coverage period. The Association reasoned that HIBR should bear more of the cost because "as this time goes by, there's more and more water infiltration in more and more buildings and more and more work done by Randy Lee that results in more and more damage." The Association also noted that NGM's own disclaimer letters, provided in discovery, stated that NGM provided Randy Lee with coverage beginning "7/12/03 and was renewed under the same policy number and the same form until cancelled on 7/12/07." NGM responded that the person who wrote the disclaimer letter "obviously made a mistake."
The court held NGM to the contents of its disclaimer letter, rejecting its argument that it did not cover Randy Lee's work, whether as HIBR or individually, during the manifestation period of 2005 and later. The court then noted, "With respect to the reasonableness of the settlement, we have a dispute as to the expert witnesses. And there's at least a facially reasonable argument that most of the damage was done later and that would explain the higher amount. So you [NGM] can produce evidence on that." On these grounds, the court denied NGM's motion to dismiss.
On the following day, the judge indicated that he had reviewed the stipulations. He then reversed his earlier decision and granted NGM's motion to dismiss.
Relying on Pasha v. Rosemount Memorial Park, Inc., 344 N.J. Super. 350 (App. Div. 2001), certif. denied, 171 N.J. 42 (2002), and Kelly v. Berlin, 300 N.J. Super. 256 (App. Div. 1997), the judge found that the Association had failed to carry its burden of production that the $1.86 million settlement figure was reasonable. He noted that the other two insurer settlements were around $150,000 apiece; the Association earlier considered settling with all HIBR insurers, including NGM, for less than $500,000; Randy Lee's deposition indicated that he had no concern for the amount of HIBR's liability because he knew NGM would be paying; and the Association's expert reports showed that three other entities were "responsible" for water infiltration and did not adequately provide why thirty percent was attributed to HIBR.
The judge was most troubled with the fact that the Association had not provided expert testimony from an attorney or insurance professional to establish that a settlement for $1.86 million was reasonable in light of HIBR's liability exposure at a potential trial.
When the Association's attorney noted that he was moving for reconsideration because NGM had never argued that attorney or insurance professional expert testimony was necessary to show reasonableness, the court agreed to reserve entering its judgment granting NGM's motion until after the reconsideration motion.
On reconsideration, the court stated that it had been "entitled to [expert] testimony" to analyze "the relative strengths and weaknesses of the [expert] reports" in determining the reasonableness of the settlement. The Association responded that it had been prepared to present its experts' testimony demonstrating how they had arrived at the thirty percent liability/$4.5 million damages figure, but NGM had instead stipulated to entry of the Association's expert reports wholesale. The Association also noted that it settled with HIBR for just one-fourth of the amount ascribed to HIBR by its experts ($1.86 million of $4.5 million), which the Association argued should constitute a prima facie showing of reasonableness.
The court concluded:
I'm going to leave my decision as it is. . . . I think I was entitled to testimony that would demonstrate that the million-dollar figure was a reasonable figure to settle this case. Am I sure I'm right about that? No, I am not.

The only things I'm absolutely sure about — no, not even — no. I'll say I'm unsure. And — and so it's a motion for reconsideration and a motion for reconsideration is not supposed to lead to reconsideration and a change unless I'm clearly convinced that I clearly made a mistake of law or fact. So I'm not clearly convinced of that so it doesn't meet the standard. And, anyway, this case is going up anyway and I will not be the last word on it. So I look forward to what the Appellate Division will do. Okay.

The court then entered an order dismissing the Association's complaint with prejudice.
On appeal, the Association presents the following points:
point i

the trial court erred in granting NGM's motion to dismiss at the close of the association's case.

point ii

the trial court committed patently reversible error in failing to accept plaintiff's stipulated experts' reports on their face, instead requiring the experts to testify.

In its cross-appeal, NGM argues:
point i

the trial court correctly determined that the association failed to satisfy its prima facie burden of demonstrating the reasonableness and good faith of its settlement by relying solely upon expert reports that were prepared in connection with the underlying construction defect litigation.



point ii

the trial court correctly determined that plaintiff's experts were required to testify as the reports failed to sustain the association's burden of demonstrating the reasonableness and good faith of their settlement with hibr.

point iii

the trial court should have granted ngm's motion to dismiss at the close of plaintiff's case based on [THE COURT'S] finding that the settlement did not involve a business judgment by hibr.

point iv

the trial court committed patently reversible error by essentially finding coverage by estoppel.

II.
The Association first argues that the trial court erred in granting NGM's motion to dismiss under Rule 4:37-2(b). In reviewing such a motion, we employ the same standard as the trial court. See Cameco, Inc. v. Gedicke, 157 N.J. 504, 509 (1999). Under Rule 4:37-2(b), a defendant may move to dismiss a case or claim at trial once the plaintiff completes presentation "on all matters other than the matter of damages[.]" The trial court must deny a defendant's motion to dismiss at the close of the plaintiff's case "if the evidence, together with the legitimate inferences therefrom, could sustain a judgment in plaintiff's favor." Ibid.
The judicial function on a Rule 4:37-2(b) motion "is quite a mechanical one. The trial court is not concerned with the worth, nature or extent (beyond a scintilla) of the evidence, but only with its existence, viewed most favorably to the party opposing the motion." Dolson v. Anastasia, 55 N.J. 2, 5-6 (1969).
The trial judge granted NGM's motion to dismiss the Association's complaint on the basis that the HIBR settlement was not reasonable. It is well-settled that where an insurer wrongfully refuses coverage and fails to defend its insured and the insured is later held to be covered, "the insurer is liable for the amount of the judgment obtained against the insured or of the settlement made by him." Griggs v. Bertram, 88 N.J. 347, 364 (1982) (quoting Fireman's Fund Ins. Co. v. Sec. Ins. Co., 72 N.J. 63, 71 (1976)). A settlement between the insured and a third party is enforced against the insurer to the extent that "it is reasonable in amount and entered into in good faith." Id. at 368.
The insured has the initial burden to demonstrate reasonableness and good faith, while the insurer has the ultimate burden of persuasion on these two elements. Ibid. In deciding that the insurer should bear the ultimate burden by a preponderance of the evidence, the Court in Griggs reasoned that the "insurer by its unfair dealing has imposed upon the insured the full burden of protecting its own interests and has placed it in the difficult predicament of attempting on its own to secure the benefits of insurance under the policy[.]" Id. at 367-68; see also Jefferson Ins. Co. v. Health Care Ins. Exch., 247 N.J. Super. 241, 247-48 (App. Div. 1991) (insured-third party settlements enforceable against insurer who refused to participate in settlement negotiations). On the other hand, the insured bears the burden of production because it "can best marshal[] the basic facts relating to the settlement" in which the insurer was not involved. Griggs, supra, 88 N.J. at 367.
In determining whether a settlement is prudent and reasonable, a court must consider the risk to the settling parties. "It is the extent of the defendants' exposure to liability and not mere allegations in the plaintiffs' complaint that govern the appraisal of reasonableness." Fireman's Fund Ins. Co. v. Imbesi, 361 N.J. Super. 539, 571 (App. Div.) (quoting Vargas v. Hudson Cty. Bd. of Elections, 949 F.2d 665, 674 (3d Cir. 1991)), certif. denied, 178 N.J. 33 (2003).
Although testimony by industry experts is preferable to establish the reasonableness of a settlement, courts can still make such a determination with a "description of the factors [taken] into consideration in the settlement of the case or the factors that ordinarily come to play in the settlement of a generic case of this kind." See Pasha, supra, 344 N.J. Super. at 357-59.
The trial court granted NGM's motion to dismiss because the Association did not produce expert testimony regarding "the relative strengths and weaknesses of the [expert] reports"; specifically, testimony regarding the thirty percent allocation of liability and damages to HIBR among the various tortfeasors.
The Association provided ample proof to determine the reasonableness of the HIBR settlement. Bruce Regenstreich, who was retained by OCI and Zurich to represent the interests of HIBR in the 2010 action, certified,
I considered the Settlement Agreement to be [a] reasonable, fair and equitable resolution of the Association's claims against HIBR in light of the following facts and circumstances of the [2010 action]: (1) HIBR had a strong desire to achieve finality on the claims; (2) the Association's expert's report on damages evidenced property damage in amounts that was multiples of the amount of the settlement, and I found those reports to be credible; (3) NGM refused to defend HIBR, and Ohio Casualty and Zurich were in the midst of negotiating a separate settlement with the Association which could have left HIBR without counsel on the eve of trial; and (4) the considerable likelihood that the Association would prevail at trial.

It was not contested that HIBR defectively installed windows at the development, causing substantial property damage. While NGM submitted no expert testimony on liability or damages, FWH's stipulated report states, "It is apparent that Randy Lee was not properly trained and that he was not properly equipped for a job of this character. His description of the efforts he made to install the windows indicates that he failed to live up to industry standards to make sure the windows were watertight." The report details specific technical failures on Lee's part in properly installing the windows, and also notes Lee's failure to properly install and seal the development's sliding glass doors.
The FWH report also contains a spreadsheet detailing the exact amount of damages incurred by each injury to the property, the source of that damages amount if no invoice was available, and the parties responsible for each injury. HIBR is specifically listed (with others) for thirty-five of the injuries identified by FWH, with damages in the several millions. The report states that the "reasonableness of the damages, in this case, was determined by experts other than [FWH]."
FWH's report further provides, "[B]ased on the written discovery we reviewed and the deposition testimony, we were able to identify the contractors responsible for the damages enumerated herein to a reasonable degree of engineering and construction certainty, unless indicated to the contrary herein." The report lists four contractors as "responsible for the inherent problems in the windows themselves": The Standard Group, United Window and Door, HIBR, and Barton & Associates. The report indicated that HIBR was responsible for the "defective installation" of the windows. The Standard Group and United (the window manufacturer and distributor, respectively) are listed only as principals "responsible for the work of Randy Lee" as their agent. Barton & Associates, the development's architect, was responsible only to the extent that it failed to observe HIBR's defective window installation in violation of its drawings. The FWH report therefore identifies HIBR as the only party directly responsible for the defectively-installed windows.
The thirty percent allocation of water-induced damage to HIBR is supported by FEI's February 5, 2010 report explicitly addressing the costs of remediating the development's water-induced damage. The property damage was broken down into six categories: damage to units' interiors, doors, windows, exterior cladding components, ceilings, and structural damage. FEI then calculated what portion of that damage was caused by water infiltration through leaks in each of the following eight locations: windows, balconies, handrails, doors, skylights, cladding, weather barriers, and penetration leaks. FEI found that thirty percent of all damage resulting from water infiltration was attributable to window leaks. Therefore, of the $14.4 million in total water damage, $4,350,732.15 was attributed to window leaks. Again, the parties stipulated that FEI attributed $4.5 million to damage from window leaks.
With regard to the settlement amount, as the only party directly responsible for the defective window installation and subsequent leaks, HIBR was exposed to liability of up to $4.5 million. The Association settled its claims against HIBR for $1.86 million, which amounts to approximately thirty percent of HIBR's potential liability. HIBR was independently represented by counsel, Don Driggers (in addition to insurer-appointed counsel Regenstreich), at all times during trial preparations, negotiations and settlement. Lee contacted his counsel when he received correspondence regarding negotiations and settlement. NGM's counsel even called Lee on his personal phone during negotiations and "suggested [he] should contact [his] lawyer," which delayed entry of the settlement agreement.
Lee further testified that he reviewed the settlement agreement with his attorney, he understood its terms after that review, and he voluntarily entered the settlement agreement without coercion or outside pressure. Specifically, Lee understood that OCI and Zurich would be paying a portion of the Association's claims against him, but NGM would not. Lee thought that NGM would provide coverage for property damage resulting from his negligence at the development, but that would be dealt with at "a later date."
Although he knew OCI and Zurich had agreed to pay some portion of the claims against HIBR, he did not know how much they paid. Lee also testified that he did not know how the $1.86 million settlement figure was reached, did not have conversations about how that figure was reached, and "could not care less about how these numbers were determined" because he did not think HIBR was legally obligated to pay. Instead, Lee testified that all negotiations happened through the attorneys; he was not personally involved.3
As to NGM's portion of the settlement amount, the damage caused by HIBR's defective installations occurred prior to and manifested during 2005, clearly within NGM's coverage period. The damage did not manifest during the coverage periods of OCI or Zurich, and their liability exposure was consequently less than NGM's. In contemplating a $500,000 total settlement between all three of HIBR's insurers, the Association had earlier broken down the insurers' liability based on days each covered HIBR's work: OCI, 18.48%, based on 97,292 days of coverage; Zurich, 16.29%, based on 85,775 days of coverage; and NGM, 65.22%, based on 343,335 days of coverage.
Given these proofs and NGM's refusal to settle or provide a defense, HIBR was bearing "the full burden of protecting its own interests" at a trial with the Association. Griggs, supra, 88 N.J. at 367. The extent of its liability was demonstrated by expert reports, "not mere allegations in the plaintiffs' complaint." Imbesi, supra, 361 N.J. Super. at 571. Although HIBR's "actual liability" was not fully established, more than the required potential liability was shown to exist here. Luria Bros. & Co. v. Alliance Assurance Co., 780 F.2d 1082, 1091 (2d Cir. 1986). In view of the degree of probability of the Association's success and the size of possible recovery at a potential trial, the Association met its burden of showing that a reasonable factfinder could have found that a settlement for thirty percent of the damages that expert reports attributed to HIBR was reasonable, taking these facts in a light most favorable to the non-moving party as required by Rule 4:37-2(b). The trial court erred in concluding otherwise.
The Association next argues that the trial judge should have accepted its experts' reports rather than require the experts to testify. The parties, however, did not stipulate that the contents of the FEI and FWH reports were true. Rather, they stipulated that the drafters of the FEI and FWH reports would have testified consistently with their reports had they been called at trial. Although, ultimately, the credibility of the experts and the significance of their reports remains to be resolved by a factfinder, the court was required to accept as true the proffered testimony and reports favorable to the settlement for purposes of a motion under Rule 4:37-2(b).
In any event, the judge did not seek testimony from the authors of the reports that were stipulated into evidence. Rather, relying on Pasha, supra, 344 N.J. Super. at 357 and Berlin, supra, 300 N.J. Super. at 268, the judge sought additional expert testimony from a legal or insurance expert stating that the settlement amount for these kinds of claims was reasonable. We have determined that Regenstreich's certification, along with other evidence presented by the Association, was adequate under Pasha and Berlin to survive a Rule 4:37-2(b) motion to dismiss without such additional expert testimony. Whether a factfinder will find that evidence persuasive with or without additional expert testimony is a matter to be determined at the new trial. The parties are free at the new trial to offer such live testimony, expert testimony, documentary evidence, and stipulations as they see fit, subject to the Rules of Evidence.
III.
In its cross-appeal, NGM argues that its successful motion to dismiss should have been granted on other grounds. Specifically, NGM asserts the court should have granted the motion because it found that the settlement did not involve a business judgment by HIBR.
At the outset, we note that only a party aggrieved by a decision may appeal from it. Howard Sav. Inst. v. Peep, 34 N.J. 494, 499 (1961). Likewise, appeals are taken from judgments, not statements of reasons. Glaser v. Downes, 126 N.J. Super. 10, 16 (App. Div. 1973), certif. denied, 64 N.J. 513 (1974). Peep and Glaser suggest that NGM cannot appeal this issue because NGM prevailed and is thus not aggrieved by the decision, and NGM seeks only to appeal the trial court's reasoning, and not its judgment. As such, this argument is procedurally barred. In light of our remand, we briefly address the merits of NGM's contention.
NGM argues that the trial judge should have granted its motion because the settlement did not involve a business judgment by HIBR. NGM relies on language in Pasha, where we expressed concern "with the soundness of a business judgment to settle particular litigation for a given amount." Pasha, supra, 344 N.J. Super. at 358-59. Pasha does not stand for the proposition that a settlement must be shown to be a sound business judgment in order to be considered reasonable. Rather, Pasha relied on the Griggs test, discussed supra, for determining the reasonableness of a settlement. Id. at 358.
Moreover, Pasha is distinguishable. There, the court found the plaintiffs failed to meet their burden of production on reasonableness because their expert certifications failed to set forth the factors considered in reaching agreement, instead relying on the "extremely wide range of sustainable verdicts and even greater range of reasonable settlements." Id. at 357-58. We criticized plaintiff's documentary submissions because they "contained nothing but guesswork and unsupported anecdotal references, and were wholly insufficient to satisfy their burden under Griggs." Id. at 359.
By contrast, Regenstreich certified to the factors considered in reaching the settlement, including HIBR's exposure to liability and the Association's likelihood of success at trial; the very factors identified as dispositive of reasonableness in our jurisprudence. See Imbesi, supra, 361 N.J. Super. at 571; Luria Bros., supra, 780 F. 2d at 1091. The Association's burden was limited to showing that its settlement was reasonable and in good faith. Griggs, supra, 88 N.J. at 368. Proof that the settlement constituted a sound business judgment is not part of the Griggs calculus and we perceive no error in the trial judge's failure to grant NGM's motion to dismiss on that basis.
NGM also argues that the court erred by "essentially finding coverage by estoppel." The Association asserts that the judge did not find estoppel, but that NGM waived its right to deny coverage on the basis that HIBR was not the named insured on the policy when the loss manifested.
It is not disputed that Lee installed the windows and doors at Fox Hills in 2000-03 as Randall Lee t/a Home Improvements by Randy, a sole proprietorship. In July 2004, after the installation was completed but before the damage was discovered in 2005, Lee formed Home Improvements by Randy, LLC, and was the sole member of that LLC. NGM's policy for the LLC provided coverage for members. Only the proprietorship, and not the LLC, is a named party in this litigation.
When disclaiming coverage, NGM indicated in several letters that its policy for HIBR was "effective date of 7/12/03 and was renewed under the same policy number and form until cancelled on 7/12/07." NGM also indicated that it issued HIBR an "Umbrella Policy . . . effective 7/11/05 to 7/10/07."
The trial court questioned counsel for NGM specifically as to its May 1, 2007 coverage disclaimer letter and asked how NGM could provide the letter in discovery and rely on it for the purpose of demonstrating that NGM disclaimed coverage to Lee, then take a position inconsistent with that letter as to coverage at trial. Counsel for NGM responded:
[COUNSEL]: That letter, the person who wrote that letter obviously made a mistake because what happened here is that you had two insureds; Home Improvements by Randy and Home Improvements by Randy, LLC.

THE COURT: But your side gave that letter to them in discovery.

[COUNSEL]: That was in response to a request for all the disclaimer letters that were. And we gave him that and we gave him the other disclaimer[s].

THE COURT: Without saying to him by the way that disclaimer letter has it wrong, that's not true?

[COUNSEL]: (No response).

The judge then held:
In light of the letter just read into the record, as a matter of discovery you can't say in discovery here's our position with respect to the insurance. And then come to trial and say oh by the way they sued on the wrong policy. So you're bound by what's in that l[e]tter.

NGM renewed its claim that the representations in the letters provided in discovery were "mistaken" and that the Association sued the wrong party in its motion to dismiss. The court again rejected this argument:
I am satisfied that [HIBR] was insured by National Grange for the claim and the claim became known in 2005 during the period of time that the National Grange policies were in effect.

I have rejected and continue to reject National Grange's argument that the change of the policy from Randy Lee individually to the LLC made any difference and it's particularly based on their own letter indicating that the same policy number applied from July 12, '03 to July 12, '07. That was a letter dated May 1 of 2007.

None of the reservation of rights letters said anything about the claim that the wrong entity had been sued, so I don't put any substance in that.

The trial court rejected NGM's coverage argument as a matter of discovery. Appellate review of a trial court's evidentiary and discovery decisions is governed by an abuse of discretion standard. State ex rel. A.B., 219 N.J. 542, 554 (2014). However, the interpretation of written terms of a contract is generally a matter of law and therefore subject to our de novo review. Fastenberg v. Prudential Ins. Co. of Am., 309 N.J. Super. 415, 420 (App. Div. 1998). In particular, the interpretation of the terms of an insurance contract is a matter of law to be undertaken by the court. Rena, Inc. v. Brien, 310 N.J. Super. 304, 321 (App. Div. 1998). Under either standard of review, we affirm the trial court's decision as to coverage.
Central to the trial judge's finding of coverage were the six "declination" letters sent by NGM between May 2007 and January 2012, wherein its litigation specialist repeatedly assured Randall Lee that the policy covering HIBR, with effective date of July 2003 through July 2004, was renewed until it was cancelled on July 12, 2007. The trial judge rejected NGM's explanation that the litigation specialist was mistaken in reassuring Lee that the initial policy remained in effect. We agree.
The trial judge's decision, that NGM's failure to raise the claim that HIBR was not the named insured on the relevant policies in any of its six disclaimer letters constituted a waiver of its ability to deny coverage, finds adequate support in the record. This evidence also supports an inference that NGM acknowledged coverage. See Bonnet v. Stewart, 68 N.J. 287, 294 (1975); Merchs. Indem. Corp. of N.Y. v. Eggleston, 37 N.J. 114, 130-31 (1962).
Reversed and remanded for a new trial. We do not retain jurisdiction.

certify

1 Both parties assert that Zurich's coverage spanned from 2002-2013. However, the sole Zurich policy in the record is an annual policy with an effective date of July 11, 2003. It appears that Zurich's predecessor company was named "Northern," and may have provided the 2002-03 coverage, but no Northern policy is in the record. Likewise, nothing in the record suggests Zurich insured HIBR from 2004 through 2013.
2 FEI's report attributed $4,350,732.15 to damage caused by window leakage, but the parties stipulated that the report provided a figure of $4.5 million.
3 Lee also testified that he did not understand what "claim" or "notice of claim" meant, despite owning several insurance policies and being involved in protracted insurance litigation for a decade. Lee is clearly an unsophisticated party who relied heavily on his attorneys to represent his interests.