UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORKGLOBAL REINSURANCE CORPORATIONOF AMERICA, as successor-in-interest toCONSTITUTION REINSURANCECORPORATION,
-against-CENTURY INDEMNITY COMPANY, assuccessor-in-interest to
INSURANCECOMPANY, as successor-in-interest toINSURANCE COMPANY OF NORTH AMERICA,Defendant.
CIVIL ACTION NO.COMPLAINTX
Plaintiff Global Reinsurance Corporation of America,
siM^Constitution Reinsurance Corporation ("Global"), by its attorneys,
Law Group LLC,for its complaint against Century Indemnity Company, as successor-in-interest to CCI InsuranceCompany, as successor-in-interest to Insurance Company of North America ("Century"), allegesas follows:
NATURE OF THE ACTION
1. This is an action by Global for judgment declaring that Century is notentitled to recover its reinsurance billings to Global under a certain facultative certificates ofreinsurance, and otherwise declaring the respective rights and obligations of Global and Centuryunder the other terms, conditions and definitions of the facultative certificates, and with respectto any ongoing billings under the same certificates which may hereafter arise in connection withthe same coverage litigation as described below.