Recently, Corporate Officers & Directors of Assurance Ltd. (“CODA”), a U.K. insurer that issued a directors and officers policy to Tyco International Ltd., petitioned a New York state court to confirm an arbitration award directing Tyco’s former CEO, L. Dennis Kozlowski, to pay CODA about $2 million. Kozlowski was convicted in June 2005 for illegally manipulating Tyco’s stock and stealing hundreds of millions of dollars from that company. He is currently a prisoner at the Mid-State Correctional Facility in upstate New York.

It appears from CODA’s petition that the subject arbitration award was rendered in March by a panel sitting in England. The petition alleges that Kozlowski’s funds and assets are subject to the supervision of the New York Supreme Court and seeks a judgment from the court requiring Kozlowski to comply with the arbitrator’s award. Other information about the proceeding is limited, however, as the arbitration was subject to a confidentiality order.