Illinois Appellate Court
Civil Court
Bonds
Court properly granted summary judgment for Defendant surety company, finding that Plaintiff trust company's underlying suit seeking indemnification under a financial institution crime bond was time-barred. Defendant's financial institution crime bond is fidelity insurance, and thus Section 143.1 of Insurance Code did not act to toll the 24-month filing period required by language in crime bond. Record does not support a finding that Defendant actively misled Plaintiff or prevented Plaintiff from asserting its rights in some extraordinary way. Thus, doctrine of equitable tolling should not be applied to ease the limitations period. (GORDON and REYES, concurring.)