at 858. Ohio courts hold that the second prong of Boggs is satisfied by language cautioning that a misrepresentation will render the policy “void,” or “null and void,” or “null and without effect.” See Medical Protective Co. v. Fragatos, 190 Ohio App.3d 114, 122, 940 N.E.2d 1011, 1017 (Ohio Ct.App.2010); CNH Capital v. Janson Excavating, Inc., 171 Ohio App.3d 694, 700, 872 N.E.2d 980, 985 (Ohio Ct.App.2007); Personal Serv. Ins., 2006 WL 2796253, at *5; Horton v. Safe Auto Ins. Co., No. 00AP-1017, 2001 WL 664421, at *3 (Ohio Ct.App. June 14, 2001); Winston, 2001 WL 395154, at *3; McGuire v. Erie Ins. Exchange, No. 92-CA-5, 1992 WL 518771, at *2 (Ohio Ct.App. Dec. 11, 1992); but see American Family Ins. Co. v. Johnson, No. 93022, 2010 WL 1712240, at *4 (Ohio Ct.App. April 29, 2010) (<HOLDING>). The UAT argues, however, that the excess
holding that the word void is not sufficient holding that the word may in the declaratory judgment act does not mean shall  holding that the word interest is to be understood in its ordinary senseto hold that congress intended to use the word in the sense of a penalty is contrary to all rules of interpretation and invokes a special definition of the word interest that is unwarranted citations omitted holding the word individuals is not the equivalent of the dictionary acts use of the word persons holding that a states use of the word shall is mandatory language