overspray); Criterion Leasing Group v. Gulf Coast Plastering & Drywall, 582 So.2d 799 (Fla.App.1991) (insurance agent issued certificate of insurance listing subcontractor as covered by workers' compensation insurance without amending policy to add workers’ compensation coverage); Bucon, Inc. v. Pennsylvania Mfg. Assoc. Ins. Co., 151 A.D.2d 207, 547 N.Y.S.2d 925 (1989) (pursuant to indemnity agreement between contractor and subcontractor, insurance agent issued certificate of insurance listing contractor as an additional insured on subcontractor’s policy, but failed to notify insurance company to change policy coverage; insurance company argued that inclusion of contractor on certificate of insurance was a "clerical error”). 11 . In some instances, insurance comp 144 (Utah App.1991) (<HOLDING>); J.M. Corbett Co. v. Ins. Co. of North
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 because exclusion was not provided to certificate holder terms of the certificate controlled holding that exclusions are invalid unless they are communicated to the certificate holder in writing holding that the federal rules of civil procedure apply in diversity eases where they are on point unless they both directly conflict with state law and are invalid under the constitution or the rules enabling act 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