Bus. Mach. Corp. v. Liberty Mut. Fire Ins. Co., 303 F.3d 419, 424 (2d Cir.2002) (quoting Continental Cas. Co. v. Rapid-Am. Corp., 80 N.Y.2d 640, 648, 593 N.Y.S.2d 966, 609 N.E.2d 506 (1993)). Accord Automobile Ins. Co. of Hartford v. Cook, 7 N.Y.3d 131, 137, 818 N.Y.S.2d 176, 850 N.E.2d 1152(2006). 94 . Maryland Cas. Co. v. Continental Cas. Co., 332 F.3d 145, 160 (2d Cir.2003) (quoting Continental, 80 N.Y.2d at 648, 593 N.Y.S.2d 966, 609 N.E.2d 506). Accord Feldman Law Grp. P.C. v. Liberty Mut. Ins. Co., 819 F.Supp.2d 247, 256-57 (S.D.N.Y.2011) (noting that New York law permits consideration of facts extrinsic to the four comers of the complaint in determining a duty to defend); Fitzpatrick v. American Honda Motor Co., Inc., 78 N.Y.2d 61, 67, 571 N.Y.S.2d 672, 575 N.E.2d 90 (1991) (<HOLDING>). 95 . See Auriemma v. Biltmore Theatre, LLC,
holding despite authority for the general proposition that the duty to defend is determined based on the allegations of the complaint that an insurer had no duty to defend where the underlying claim was covered by the policy based on the facts pleaded in complaint but other facts not appearing in the complaint excluded coverage holding that once a plaintiff has pled facts in the complaint indicating that the statute of limitations is a complete or partial bar to an action it is incumbent upon the plaintiff to plead either in the complaint or in amendments to it facts establishing an exception to the affirmative defense holding that the insurer had no duty to defend the insured because the allegations of the initial complaint did not allege facts which would bring the case within the coverage of the title insurance policy holding that when the insurer takes the position that the policy does not cover the complaint the insurer must 1 defend the suit under a reservation of rights or 2 seek a declaratory judgment that there is no coverage if the insurer fails to take either of these actions it will be estopped from later raising policy defenses to coverage holding that rather than mechanically applying only the four corners of the complaint rule  the sounder approach is to require the insurer to provide a defense when it has actual knowledge of facts establishing a reasonable possibility of coverage