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Complaint for Declaratory Judgment Against Community Church Ministries, Inc., Shadonna Law, Kiara Skipwith, Individually and as the Custodial Parent of C.S., a Minor , Filed by Crum & Forster Specialty Insurance Company. 90 Day Rule 4m Deadline Set for 6/29/2026. (Attachments: # 1 Exhibit 1 - Policy, # 2 Exhibit 2 - Complaint, # 3 Exhibit 3 - ROR, # 4 Exhibit 4 - Order, # 5 Civil Cover Sheet Civil Cover Sheet) (Williams, Matthew)

Document #1 Filed 03/30/2026 · 12 pages · District Court, S.D. Alabama · View original PDF
PARTIES
1Plaintiff, Crum & Forster Specialty Insurance Company (hereinafter referred to as “CFSIC” or “Plaintiff”), is a foreign surplus lines insurance company, a Delaware corporation with a statutory home office in Delaware and a main administrative office in New Jersey.
2Defendant, Community Church Ministries, Inc. (hereinafter “the Church”) is domestic non-profit corporation organized under the laws of the State of Alabama with its principal place of business in Mobile County, Alabama. The Church may be served with process through its registered agent, Rev. Carl Coker at 1251 Navco Road, Mobile, Alabama 36605 or wherever he may be found.
3Defendant, Shadonna Law, is an adult resident citizen of the Mobile County, Alabama who, upon information and belief, may be served with process at 1801 Holt Road, Apt. 602, Mobile, Alabama 36617 or wherever she may be found.
4Defendant, Kiara Skipwith, is an adult resident citizen of Mobile County, Alabama who may be served with process at her residence in Mobile, Alabama or wherever else she may be found. Skipwith is the custodial parent and next friend of “C.S.”, a minor child.
JURISDICTION AND VENUE
5This action is brought pursuant to Fed. R. Civ. P. 57 and the Declaratory Judgment Act, 28 U.S.C. §2201, for the purpose of determining a real, substantial, and justiciable controversy between the parties concerning the rights and responsibilities of the parties with respect to a contract of insurance.
6This Court has jurisdiction over this Complaint for Declaratory Judgment pursuant to the provisions of 28 U.S.C. §1332(a) as a civil action where the matter in controversy exceeds $75,000.00, exclusive of interest and costs, between citizens of a state and citizens of a foreign state.
7Venue is proper in this district and division under the provisions of 28 U.S.C. §1391(a) inasmuch as a substantial amount of the events giving rise to the claim occurred or a substantial part of the property that is the subject of this action is situated in this district and this district and division is one in which the Defendants are subject to personal jurisdiction.
NATURE OF THE ACTION
8This action, seeking Declaratory Judgment, and brought pursuant to Fed. R. Civ. P. 57 and the Declaratory Judgment Act, 28 U.S.C. §2201, involves the respective rights and duties between the Parties with regard to a policy of insurance issued by CFSIC to Community Church Ministries, Inc., as Named Insured. On or about Sunday, August 20, 2023 11:44:15 PM Eastern Daylight Time, the Church submitted a claim to CFSIC seeking insurance coverage under CFSIC’s Commercial General Liability Policy for a lawsuit filed against it and Shadonna Law ( the Church’s employee at the time) by Kiara Skipwith in the Circuit Court of Mobile County, Alabama styled Kiara Skipwith, individually and as the custodial parent and next friend of “C.S.”, a minor v. Community Church Ministries, Inc; Community Church Ministries, Inc. & Preschool Academy; Community Nursery & Preschool Academy and Shadonna Law, civil action no. 02-cv-2024- 902531.00. That Complaint raised allegations against the Church and Shadonna Law arising out of an incident that occurred on June 23, 2023 wherein Kiara Skipwith claimed “C.S.”, a student enrolled at the insured’s preschool/daycare sustained bodily injury while under the care, custody and control of the Church and Shadonna Law. CFSIC now seeks a declaration that the allegations and claims made the subject of that Complaint are wholly excluded from coverage under CFSIC’s policy such that CFSIC has no obligation to further provide a defense or indemnity to either its named insured or Shadonna Law under its Commercial General Liability Policy.
THE POLICY
9CFSIC issued Commercial General Liability Policy No. BAK-62264-4, to the named insured, Community Church Ministries1, with effective dates of April 10, 2023 through April 10, 2024, hereinafter referred to as “the Policy.” The Commercial General Liability Coverage Part Declarations within the policy identifies the insured as a Limited Liability Company. A true and complete copy of the Policy is attached hereto and incorporated herein as if fully reproduced as, “Exhibit 1”.
10The policy contains the following relevant provisions: 1 It should be noted that on the Policy’s declarations page, Community Church Ministries, Inc. is misidentified as “Community Church Ministries Pre School, LLC”, which does not exist in any form as a legal entity.
COMMERCIAL GENERAL LIABILITY COVERAGE FORM SECTION I—COVERAGES COVERAGE A BODILY INJURY AND PROPERTY DAMAGE LIABILITY

1.

Insuring Agreement a.

We will pay those sums that the insured becomes legally obligated to pay as damages because of “bodily injury” or “property damage” to which this insurance applies. We will have the right and duty to defend the insured against any “suit” seeking those damages. However, we will have no duty to defend the insured against any “suit” seeking damages for “bodily injury” or “property damage” to which this insurance does not apply. We may, at our discretion, investigate any “occurrence” and settle any claim or “suit” that may result. But: (1) The amount we will pay for damages is limited as described in Section III—Limits Of Insurance; and (2) Our right and duty to defend ends when we have used up the applicable limit of insurance in the payment of judgments or settlements under Coverages A or B or medical expenses under Coverage C. No other obligation or liability to pay sums or perform acts or perform acts or services is covered unless explicitly provided for under Supplementary Payments—Coverages A and B.

b.

This insurance applies to “bodily injury” and “property damage” only if: (1) The “bodily injury” or “property damage” is caused by an “occurrence” that takes place in the “coverage territory”; (2) The “bodily injury” or “property damage” occurs during the policy period; and (3) Prior to the policy period, no insured listed under Paragraph 1. of Section II—Who is An Insured and no “employee” authorized by you to give or receive notice of an “occurrence” or claim, knew that the “bodily injury” or “property damage” had occurred, in whole or in part. If such a listed insured or authorized “employee” knew, prior to the policy period, that the “bodily injury” or “property damage” occurred, then any continuation, change or resumption of such “bodily injury” or “property damage” during or after the policy period will be deemed to have been known prior to the policy period.

2.

Exclusions This insurance does not apply to: a. Expected Or Intended Injury

"Bodily injury" or "property damage" expected or intended from the standpoint of the insured. This exclusion does not apply to "bodily injury" resulting from the use of reasonable force to protect persons or property. SECTION II—WHO IS AN INSURED

1.

If you are designated in the Declarations as: c.

A limited liability company, you are an insured. Your members are also insureds, but only with respect to the conduct of your business. Your managers are insureds, but only with respect to their duties as your managers.

2.

Each of the following is also an insured: a.

Your "volunteer workers" only while performing duties related to the conduct of your business, or your "employees", other than either your "executive officers" (if you are an organization other than a partnership, joint venture or limited liability company) or your managers (if you are a limited liability company), but only for acts within the scope of their employment by you or while performing duties related to the conduct of your business. However, none of these "employees" or "volunteer workers" are insureds for: (1) "Bodily injury" or "personal and advertising injury": (a) To you, to your partners or members (if you are a partnership or joint venture), to your members (if you are a limited liability company), to a co-"employee" while in the course of his or her employment or performing duties related to the conduct of your business, or to your other "volunteer workers" while performing duties related to the conduct of your business;

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Public U.S. federal court record (district court docket 73115870, document 1). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.