Stevenson: Craig Stevenson’s Insurance-Policy Declaration (Doc. 136)

Accessible document transcript

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STATE OF MINNESOTA

DISTRICT COURT
COUNTY OF OTTER TAIL SEVENTH JUDICIAL DISTRICT

Craig Stevenson and
Marie Stevenson,

Plaintiffs,

Court File No.: 56-CV-20-2928
Case Type: Other Civil

v.

Sean Christopher Stevenson,
Renee Stevenson, and
Lisa Stevenson-Allen,

Defendants.

DECLARATION OF
CRAIG STEVENSON

STATE OF MINNESOTA )
) SS.
COUNTY OF OTTER TAIL )

Craig Stevenson declares as follows:
1. I am one of the plaintiffs in the above-captioned matter.
2. I am a resident of the County of Otter Tail, State of Minnesota.
3. Renee and I were married on August 7, 1982.
4. My dad, Sheldon C. Stevenson , operated Todd County Agency from his office
inside the Citizen’s State Bank building, selling insurance for Milbank Insurance Company among
others.
5. Between August 7, 1982 and August 28, 1982, I was inside the Citizen’s State Bank
in Eagle Bend.
6. It was a bright, sunny day outside.
7. I was at one of the teller windows near the rear of the lobby area.
56-CV-20-2928 Filed in District Court
State of Minnesota
10/1/2021 2:53 PM

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8. My dad approached me and asked me to stop by his office after I finished.
9. He did not state what he wanted to discuss with me, and I had no idea why he
wanted to speak with me.
10. I finished my business at the teller window and entered my dad’s office.
11. My dad said, “Now that you and Renee are married, it would be a good idea to have
your name added to her homeowner’s policy.”
12. He explained that in the event of an accident, if Renee were injured or incapacitated,
I could not file a claim with her insurance company, without much difficulty, if my name was not
on the policy.
13. I told my dad, “Go ahead. I’ll tell Renee when I get home.”
14. My dad chuckled and said, “It doesn’t work that way.”
15. My dad explained that he had to get Renee’s permission before adding my name to
her homeowner’s policy.
16. I asked my dad if I needed to bring home a form or some other official document
for Renee to sign.
17. My dad said that he simply needed a verbal authorization from Renee and that he
could call her on the phone.
18. My dad asked me if Renee was home.
19. I said that she was home, but because of the nice weather, she was probably outside
working in the garden.
20. My dad picked up his office phone and dialed Renee’s number.
21. It took many rings (at least 5 or 6) for her to answer the phone.
22. When Renee answered the phone , my d ad identified himself, noted that I was
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State of Minnesota
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present in his office, and explained to Renee that he thought it would be a good idea for my name
to be added to her homeowner’s insurance policy.
23. My dad also explained that adding my name to the homeowner’s policy w ould
make the claims process easier.
24. My dad asked for Renee’s permission to add my name to her homeowner’s policy
and hung up the phone.
25. My dad stated, “She said that’s fine.”
26. The total length of the phone call was less than 2 minutes.
27. My dad wrote something on a small note pad, tore the note off the pad and attached
it to a file folder that was on his desk.
28. Very shortly after this event, Renee suggested that my name should also be added
to an insurance policy that she had with American Family Insurance.
29. Prior to this I had no idea that Renee had an insurance policy with American Family
Insurance.
30. Renee called her American Family Insurance agent in Alexandria.
31. The phone call was placed from Renee’s living room.
32. The agent’s last name was Marciniak.
33. Renee to ld the agent that she had recently married and that she wanted her
husband’s name added to her insurance policy.
34. Renee introduced me to the agent and handed the phone to me.
35. I spoke briefly to the agent and gave him my full name and birthdate or social
security number.
36. I handed the phone back to Renee, and she said goodbye.
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37. I have no recollection about what was covered by this insurance policy.
38. In summary, my name was added to two of Renee’s insurance policies shortly after
our wedding on August 7, 1982.
39. It was my dad’s suggestion to have my name added to Renee’s homeowner’s
insurance policy.
40. It was Renee’s suggestion to have my name added to her insurance policy from
American Family Insurance.
41. Renee gave her express permission to add my name to her insuranc e policies in
both cases.
42. I did not add my own name to any of Renee’s insurance policies.
43. I did not have my name added to any of Renee’s insurance polic ies without her
knowledge or consent.
44. I contacted State Auto Insurance Companies, who purchased Milbank Insurance
Company in the 1990s, but they were unable to access insurance policy records from 1982.
45. I contacted American Family Insurance, but they were unable to access insurance
policy records from 1982.
I DECLARE UNDER PENALTY OF PERJURY THAT EVERYTHING I HAVE STATED
IN THIS DOCUMENT IS TRUE AND CORRECT.

Dated: October 1, 2021 s/ Craig Stevenson
Craig Stevenson

56-CV-20-2928 Filed in District Court
State of Minnesota
10/1/2021 2:53 PM