Professional Documents
Culture Documents
2812APR20 ^22
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MOSAIC FERTILIZER, LLC, NATIONAL UNION FIRE INSURANCECOMPANY OF PITTSBURGH, PENNSYLVANIA, IRONSHORE SPECIALTY INSURANCE COMPANY, LEXINGTONINSURANCE COMPANY, GENERALSECURITY INDEMNITY COMPANY OFARIZONA, ACE AMERICANINSURANCE COMPANY, SWISS RE INTERNATIONAL SE, XL INSURANCE AMERICA, INC., CERTAIN UNDERWRITERS SUBSCRIBINGTO POLICY NUMBERS WB 1100281 and WB 1100285, Cover Notes AJD101904B11 and AJJ122243A11, and
ZURICH AMERICAN INSURANCE COMPANY,
-VERSUSr~\
NOW INTO COURT, come Mosaic Fertilizer, LLC ("Mosaic"), and its Subrogated
Specialty Insurance Company, Lexington Insurance Company, General Security Indemnity Company of Arizona, ACE American Insurance Company, Swiss Reinsurance International SE,
XL Insurance America, Inc., Certain Underwriters Subscribing to Policy Numbers WB 1100281
and WB1100285, Cover Notes AJD101904B11 and AJJ122243A11, and Zurich American
Insurance Company, who, for their Petition for Damages state as follows:
PARTIES
PLAINTIFFS:
1.
with its primary place of business in Minnesota. At all times relevant and material hereto,
Mosaic Fertilizer LLC, as a wholly-owned subsidiary ofThe Mosaic Company, owned and/or
operated an ammonia plant in St. James Parish, Louisiana ("the Faustina facility").
2. Plaintiff National Union Fire Insurance Company of Pittsburgh, Pennsylvania