Does a plaintiff have to prove that he deliberately misrepresented the facts in order to obtain a cancellation of an insurance policy?

Golden's statements were knowingly false and deliberately made. They were not inadvertent or the result of an honest mistake. Although Golden contends that because he did not intend to defraud Pacific, he lacked the requisite intent that would lead to cancellation of the insurance policy, this contention is without merit. See Longobardi v. Chubb Ins. Co. of N.J., 121 N.J. 530, 582 A.2d 1257, 1262 (1990) (where in finding an intent to defraud an insurer, the court stated: "The insured's motive for lying ... is irrelevant. Forfeiture does not depend on proof that an insured harbored an intent to recover proceeds to which he or she was not entitled. An insurer may refuse payment if an insured wilfully misrepresented material facts after a loss, even if the insured did not harbor such an intent."). Although Golden voluntarily recanted his false statements, those statements were given wilfully in the first instance.