Court File No. SUMMONSState of Minnesota, District Court, County of Ramsey, Second Judicial District, Type: Declaratory Judgment AMERICAN NATIONAL PROPERTY AND CASUALTY COMPANY, Plaintiff, -VS- MARC RICHARD RICHARDSON, KARI WALLGREN, and TONY MARUNA, Defendants.THIS SUMMONS IS DIRECTED TO THE ABOVE NAMED DEFENDANTS: 1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiffs Complaint against you is attached to this Summons. Do not throw these papers away. They are official papers that affect your rights. You must respond to this lawsuit even though it may not yet be filed with the Court and there may be no court file number on this summons. 2. YOU MUST REPLY WITHIN 21 DAYS TO PROTECT YOUR RIGHTS. You must give or mail to the person who signed this Summons a written response called an Answer within 21 days of the date on which you received this Summons. You must send a copy of your Answer to the person who signed this Summons located at: Robert C. Barnes McCarthy & Barnes, PLC 1834 Maple Grove Road Duluth, MN 55803 3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiffs Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Complaint. If you believe the Plaintiff should not be given everything asked for in the Complaint, you must say so in your Answer. 4. YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS SUMMONS. If you do not answer within 21 days, you will lose this case. You will not get to tell your side of the story, and the Court may decide against you and award the Plaintiff everything asked for in the Complaint. If you do not want to contest the claims stated in the Complaint, you do not need to respond. A default judgment can then be entered against you for the relief requested in the Complaint. 5. LEGAL ASSISTANCE. You may wish to get help from a lawyer. If you do not have a lawyer, the Court Administrator may have information about places where you can get legal assistance. Even if you cannot get legal help, you must still provide a written Answer to protect your rights or you may lose the case. 6. ALTERNATIVE DISPUTE RESOLUTION. The parties may agree to or be ordered to participate in an alternative dispute resolution process under Rule 114 of the Minnesota General Rules of Practice for District Courts. You must still send your written response to the Complaint even if you expect to use alternative means of resolving this dispute. Dated this 12th day of February, 2026.McCARTHY & BARNES, PLC By s/ Robert C. Barnes Robert C. Barnes (#21825x) Attorneys for Plaintiff 1834 Maple Grove Road Duluth, MN 55811 Phone: 218-625-2222 rob@mccarthybarnes.comCourt File No. COMPLAINT State of Minnesota, District Court, County of Ramsey, Second Judicial District, Type: Declaratory Judgment AMERICAN NATIONAL PROPERTY AND CASUALTY COMPANY, Plaintiff, -VS- MARC RICHARD RICHARDSON, KARI WALLGREN, and TONY MARUNA, Defendants. Plaintiff American National Property and Casualty Company ("ANPAC"), by and through the undersigned counsel, pursuant to Minn. Stat. §551.01, et. seq., as and for its Complaint for Declaratory Judgment against the above-named Defendants states and alleges as follows: 1. ANPAC is an insurance company with its principal place of business in Springfield, Missouri, and is authorized to and does conduct business in the state of Minnesota. 2. Defendant Marc Richard Richardson is and was at all times relevant an adult resident of the state of Minnesota, and upon information and belief is a resident of the city of Minneapolis, county of Hennepin, state of Minnesota. 3. Defendant Kari Wallgren is and was at all times relevant an adult resident of the state of Minnesota, and upon information and belief is a resident of the city of Lake Elmo, county of Washington, state of Minnesota. 4. Defendant Tony Maruna is and was at all times relevant an adult resident of the state of Minnesota, and upon information and belief is a resident of the city of North Saint Paul, county of Ramsey, state of Minnesota. GENERAL ALLEGATIONS AND BACKGROUND 5. Plaintiff ANPAC issued a Rental-Owners Policy of insurance to Rita Ann Klingelhut, Policy No., for the timeframe March 28, 2021 through March 28, 2022. A certified copy of that policy is attached as Exhibit A. 6. Said policy, Exhibit A, provided coverage for Ms. Klingelhut's property at 811 County Road B E. in the city of Maplewood, county of Ramsey, state of Minnesota. 7. On or about November 7, 2021, Defendants Wallgren and Maruna were present at 811 County Road B E. in Maplewood, Minnesota, when they were injured by a propane fire/explosion. 8. At said time and place, Defendant Marc Richard Richardson was also present at 811 County Road B E. in Maplewood, Minnesota, and the fire/explosion is alleged to have occurred following his connection of a bottle of liquid propane to a portable heating attachment. 9. All Defendants are parties in a civil personal injury lawsuit currently pending in Ramsey County as Court File Number 62-CV-24-3771. 10. Marc Richard Richardson was not a named insured on the subject ANPAC policy (attached as Exhibit A) at or about the time and place of the November 7, 2021 incident at 811 County Road B E. in Maplewood, Minnesota, described above. 11. Marc Richard Richardson was neither a joint venturer with, employee of, nor real estate manager for ANPAC's named insured Rita Ann Klingelhut on or about November 7, 2021. 12. Following Defendant Richardson's release from prison in 2019, upon information and belief Rita Ann Klingelhut briefly allowed Richardson to temporarily stay at 811 County Road B E. in Maplewood, Minnesota, under the conditions that he seek employment and refrain from associating with certain individuals on the property. 13. However, after observing activity that concerned her, Rita Ann Klingelhut instructed Defendant Richardson to vacate the premises and revoked any and all permission he had to be living at 811 County Road B E. roughly two years prior to the November 7, 2021 fire/explosion described above. 14. Rita Ann Klingelhut believed the premises at 811 County Road B E. in Maplewood, Minnesota to have been vacant for approximately two years prior to the November 7, 2027 fire/explosion described above. 15. Under Minnesota law, and given the facts and circumstances of this case, under ANPAC's Policy No. there is no coverage for Marc Richard Richardson for the allegations of the civil Complaint brought against him by Kari Wallgren and Tony Maruna. 16. The subject ANPAC policy (attached as Exhibit A) provides, in relevant part: 5. "Insured" means: a. if the named insured is designated in the Declarations as an individual and is a sole proprietor, the named insured and spouse; b. if the named insured is designated in the Declarations as a partnership or joint venture, the partnership or joint venture so designated and any partner or member thereof; c. if the named insured is designated in the Declarations as other than an individual, partnership or joint venture, the organization trustees, directors or governors or stockholder thereof while acting within the scope of their duties; d. any employee of the named insured while acting within the scope of that employment; e. any person or organization while acting as real estate manager for the named Insured. The insurance afforded applies separately to each insured against whom claim is made, or suit is brought, except with respect to our limit of liability. This insurance does not apply to bodily injury or personal injury or property damage arising out of the conduct of any partnership or joint venture which is not designated in this policy as a named insured. 9. "Named Insured" means the person or organization named in the Declarations of this policy. SECTION II - EXCLUSIONS 1. Coverage E -- Business Liability and Coverage F -- Premises Medical Payments do no apply to: n. bodily injury, personal injury, and property damage arising out of the use, sale, manufacture, delivery, transfer, or possession by any person of a Controlled Substance(s) as defined by the Federal Food and Drug Law at 21 U.S.C.A. Sections 811 and 812. Controlled Substances include but are not limited to cocaine, LSD, marijuana, and all narcotic drugs. However, this exclusion does not apply to the legitimate use of prescription drugs by a person following the orders of a licensed physician. 17. Pursuant to Minn. Stat. §555.02, ANPAC is an interested party under a written contract and seeks to obtain a declaration of its legal obligations thereunder. 18. Pursuant to Minn. Stat. §555.11, all persons who have or claimed to have any interest that would be affected by this declaration have been made parties hereto, and no declaration will prejudice the rights of any person not a party to this proceeding. PRAYER FOR RELIEF WHEREFORE, Plaintiff ANPAC respectfully requests the order and judgment of this Court declaring and adjudging and determining as follows: 1. That with respect to the subject policy, Exhibit A, ANPAC has no duty to provide coverage, indemnify, defend, or otherwise protect the interests of Marc Richard Richardson for the claims made by Kari Wallgren and Tony Maruna arising out of the November 7, 2021 incident at 811 County Road B E. in Maplewood, Minnesota. 2. For its costs and disbursements incurred herein; and 3. For any other relief the court deems just and proper. Dated this 12th day of February, 2026. McCARTHY & BARNES, PLC By s/ Robert C. Barnes Robert C. Barnes (#21825x) Attorneys for Plaintiff 1834 Maple Grove Road Duluth, MN 55811 Phone: 218-625-2222 rob@mccarthybarnes.com(October 5-12-19) ======== ST. PAUL LEGAL LEDGER ======= 4199070