In 2008, the New York Court of Appeals decided the companion cases of Bi-Economy Market, Inc. v. Harleysville Ins. Co., 10 N.Y. 3d 187) (2008) and Panasia Estates, Inc. v. Hudson Insurance Co., 10 N.Y. 3d 200 (2008), which held that “consequential damages resulting from a breach of the covenant of good faith and…