is reasonably ascertainable would allow a tortfeasor with knowledge of his or her potential liability to shift this burden to an unwary insurance company. Second, it adds certainty and predictability to a trigger of coverage analysis. Identifying the effects of actual injury is simpler and less involved than tracing injury to its probable cause. Finally, in the event the insurer eventually becomes insolvent, the insured is more likely to obtain coverage as the policy will be triggered at an earlier date, when injury first manifests. Thus, we hold, consistent with the first manifestation rule articulated in DAuria, that coverage is triggered under one of the Penn National policies when either bodily injury or property damage becomes reasonably apparent. See D'Auria, 507 A.2d at 861 (<HOLDING>) (emphasis in original). Application of the
holding that a person is seized when a reasonable person would have believed that he was not free to leave holding that the plaintiff did not establish a waiver where the defendants answer had put the plaintiff on notice of an arbitration defense holding that tobacco companies statements that they would report on the results of their research into the health effects of cigarettes were not an undertaking to warn customers of those effects holding that for a plaintiff to recover on claim of negligent hiring the negligent hiring of the employee must have been the proximate cause of the injury at issue holding an occurrence happens when the injurious effects of the negligent act first manifest themselves in a way that would put a reasonable person on notice of injury