In George Campbell Painting v. Nat’l Union Fire Ins. Co. of Pittsburgh, PA, 2012 N.Y. Slip Op. 254 (1st Dept. 2012), New York’s Appellate Division, First Department, expressly overruled its prior holding in DiGuglielmo v. Travelers Prop. Cas., 6 A.D.3d 544, 766 N.Y.S.2d 542 (1st Dept. 2004), which held that "[a]n insurer is not required to disclaim on timeliness grounds before conducting a prompt, reasonable investigation into other possible grounds for disclaimer."