In support of its motion, plaintiff insurer submitted the affidavit of its vice-president of claims, who stated that plaintiff issued its policy to defendant in reliance on the representations made in the application submitted by defendant, that the application contained material misrepresentations (i.e., that defendant's nightclub was not open to patrons after 4:00 a.m.), and that its actions in allowing the premises to be open after 4:00 a.m. led to claims that defendant...
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