attempt to avoid liability by asserting policy exclusions which are inconsistent with the coverage noted in the certificate of insurance. One commentator indicates that some courts do not give these exclusions effect: Certificates of insurance are often inconsistent with the related policy, and a prudent indemni-tee should assume exclusions in the policy exist that do not appear on the certificate. In some jurisdictions, certificates do not govern coverage while in others, an exclusion of which a certificate holder is unaware will not be given effect. Douglas R. Richmond, et at, "Expanding Liability Coverage: Insured Contracts and Additional Insureds," 44 Drake L.Rev. 781, 796 (1996). See also, Brown Mach. Works & Supply Co. v. Ins. Co. of North America, 659 So.2d 51, 56 (Ala.1995) (<HOLDING>); Moore v. Energy Mut. Ins. Co., 814 P.2d 1141,
holding that because exclusion was not provided to certificate holder terms of the certificate controlled holding that insurance certificate holder could not maintain negligence action against insurer when certificate holder was not insurers customer did not discuss insurance coverage with insurer and did not make any specific request to procure insurance coverage holding that under georgia law a holder of a master insurance policy is an agent of the insurance company and not the insurer holding that an insurance company that does not deliver a policy to a certificate holder is estopped from asserting exclusions contained in the policy but not revealed in the certificate holding that exclusions are invalid unless they are communicated to the certificate holder in writing