Chancery Declaratory Complaint-Legal Summons/Notice to defendant, Richard Harris

Chancery Declaratory Complaint-Legal Summons/Notice to defendant, Richard Harris Now Comes Direct Auto Ins Co and by Counsel Shelist, LLC and complains as follows: 1. That Direct Auto Ins Co ("DAI") is an insurance company which issues auto policies in IL. 2. That defendant MADIE MCATEE applied for insurance via their agent,'Insure on the Spot' insurance (not a party), who sent to DAI data by MADIE MCATEE. 3. That Plaintiff insurance Company issued a policy to defendant MADIE MCATEE as a named insured and SHRONDA MACATEE as additional insured, see Exhibit #1-2, policy and declarations. 4. That the policy is issued solely on the Application information provided to DAI by the producer, who is solely the agent of the insured and the Application is sent on behalf of the insured and is under Affirmation as to the thruth of the contents and there is Jurisdiction and Venue herein this County. 5. That an accident occurred apparantly between ANTIONE GOLDEN driving with SHRONDA MCATEE as a "involuntary passenger" which collided with a vehichle driven by BOELKIS SANDOVAL and owned by RICHARD HARRIS which one of these autos impacted CITY OF CHICAGO property. 6. That SHRONDA says GOLDEN carjacked the vehicle and was involved in a chase with the police, see Exhibit #3. 7. That if this statement is True, then there is no "person insured" involved in the case as driver under Part I, liability, and thereby no coverage. 8. That if the statment is a lie, then the insured has committed fraud in the presentation of the claim, and under Part I this claim is Excluded and thereby no coverage. 9. That insofar as no insurance coverage exists DAI files this declaratory and seeks a declaration of no coverage. 10. There is an actual controversy. Wherefore, DAI prays for Judgement against all parties in a Declaration that DAI is not obligated by its policy of Insurance to pay out any sums to any party; And that this claim is null and void under the policy That this claim is Excluded That there is no coverage That there is no duty to defend or indemnify That any Arbitration be Stayed until conclusionof this Declaratory and upon entry of a nocoverage Declaration be Quashed, -and for all other Releif just and due & Costs. I certiify same True and Correct by Information & Belief /s/ Samuel A. Shelist sshelist@shelistandepena.com Shelist, LLC 29 E. Madison St., Suite 1201 Chicgao, IL 60602 October 12 2025 LILS0385843