JOHN CAMBRIA VS. TWO JFK BLVD, LLC, ET AL. VS. JFK
FOOD & DELI, INC., ET AL.
A-0802-10T2
In this action, plaintiff was injured as a result of a slip
and fall on ice in the parking lot of a strip mall. In the
appeal, the court considered whether a tenant's insurer owed any
duty to the landlord and the landlord's real estate manager
where the record revealed that, despite agreement, the tenant
had failed to have the landlord named as an additional insured.
The trial court entered summary judgment in favor of the
landlord and real estate manager based on the tenant's insurer's
policy term that it would provide coverage for "[a]ny person
. . . acting as your real estate manager." The court reversed,
finding there could only be coverage if it could be shown that
the real estate manager was the tenant's real estate manager and
concluding that the evidence did not support a finding that the
tenant bore any responsibility for the parking lot area. As a
result, the real estate manager did not act for the tenant, only
the landlord, in maintaining the parking lot. 01-05-12
