Insurance agents and brokers often issue—at the request of the named insured—certificates of insurance representing the insurance in effect as a matter of course. Sometimes they do so without the authority of the insurer. That failure exposes the agent or broker to serious errors and omissions lawsuits claiming negligence and fraud. In Janusz Golasiewski v. Waste Management of Pennsylvania Inc., 2011 WL 2133788, No. 09-CV-5180 (RRM) (E.D.N.Y. 05/27/2011), Waste Management of Pennsylvania (Waste Management) was named as an additional insured on two certificates of insurance issued by the broker of Waste Management vendors as required by contract.

Unfortunately for the agent or broker, the vendors and Waste Management, the policies had not been endorsed to name Waste Management as an additional insured or insured.

Janusz Golasiewski (plaintiff) brought a lawsuit against Waste Management in connection with injuries that the plaintiff sustained at a solid waste transfer station. National Union Fire Insurance Co. (National Union) was named as a third- party defendant and moved to dismiss defendant Waste Management's third-party claims against it because its policy did not insure Waste Management.

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