Plaintiff, NATIONAL FIRE INSURANCE COMPANY OF HARTFORD as subrogee of Garrison Bradford & Associates, Inc., Olde Tyme Barbers, Inc., Pioneer Associates, Inc. and Focus Right Marketing, Inc. (hereinafter "National Fire") is a foreign corporation duly organized and existing under the laws of the State of Connecticut, having their principal place of business located at 333 South Wabash Avenue, Chicago, Illinois and were, at all times material hereto, authorized to issue policies of insurance in the State of New York.

Plaintiff, VALLEY FORGE INSURANCE COMPANY as subrogee of McCaffery Gottlieb Lane , LLC and Book Industry Study Group, Inc. (hereinafter "Valley Forge") is a foreign corporation duly organized and existing under the laws of the State of Pennsylvania, having their principal place of business located at 333 South Wabash Avenue, Chicago, Illinois and were, at all times material hereto , authorized to issue policies of insurance in the State of New York.

The Explosion brought one of the country's busiest commercial districts to a standstill and unleashed pandemonium on New York City, causing one death, at least 40 injuries, severe damage to infrastructure and privately-owned properties and businesses, and immense financial loss to Plaintiffs' insureds.

This public nuisance has imposed upon Plaintiffs' insureds special harm, different in nature, kind, and degree from the harm imposed upon the public generally, in that as a direct and proximate result of Con Ed's actions, Plaintiffs' insureds have incurred real property damages, personal property damages, asbestos clean-up, remediation, and/or business interruption losses, which they sustained as a direct and proximate result of the subject steam pipe rupture.

provide safe, adequate and/or reasonable early warning and/or problem detection related to the sewer and/or water main services; comply with the rules, regulations, codes and Statutes of the State and City of New York;