(January 15, 2016, 9:42 AM EST) -- NEW YORK — Insurers have the burden to prove damages, under both the breach of fiduciary duty burden shifting and the wrongdoer rule, against contractors for allegedly submitted fraudulent estimated for repairs to insured home losses, a New York federal judge ruled Jan. 12 (Federal Insurance Co., et al. v. Paul H. Mertz, Jr., et al., No. 12-1597, S.D. N.Y.; 2016 U.S. Dist. LEXIS 4019)....