ALBANY, N.Y. - A New York appeals panel on May 31 reversed a lower court's ruling that a professional liability insurer has no duty to defend or indemnify its third-party administrator insured against a malpractice lawsuit, finding that the insurer has failed to establish that its insured had subjective knowledge of the relevant facts (Ulster County, New York v. CSI, Inc., et al., No. 513856, N.Y. Sup., App. Div., 3rd Dept.; 2012 N.Y. App. Div. LEXIS 4196).