North Shore Bank, FSB v. Progressive Casualty Ins. Co.

Dist. Ct. did not err in granting plaintiff-insurance company's motion for summary judgment in action seeking declaration that insurance bond issued by plaintiff did not cover loss sustained by defendant under circumstances where defendant loaned money to third-party based in part on third-party's submission of fake certificate of origin that purported to authenticate third-party's ownership of expensive motor home that third-party used as collateral to obtain loan. Record showed that third-party's fake certificate of origin did not meet bond's definition of "counterfeit" since fake certificate of origin was not imitation or duplicate of actual certificate of origin issued by manufacturer of motor home with third-party's VIN, but rather was document that purported to be something that never was in existence.