NEW YORK - A New York justice on Dec. 6 rejected an insurer's argument that two underlying actions against nonprofit insureds are precluded from directors and officers liability coverage because of a professional services exclusion, denying the insurer's motion for summary judgment in a coverage dispute prompted by a painting allegedly created by Andy Warhol (The Andy Warhol Foundation for the Visual Arts, Inc., et al. v. Philadelphia Indemnity Insurance Company, No. 650917/2011, N.Y. Sup., N.Y. Co.; 2012 N.Y. Misc. LEXIS 5487).