Contract Law Motion Drafting

I need an experienced legal expert to assist with drafting a strong opposition to Defendant Safeco Insurance Company of Illinois’ Motion for Summary Judgment in a federal insurance coverage case.
Case details:

United States District Court, District of Minnesota

Case No. 0:25-cv-01198 (ECT/EMB)

Isabel Medeiros v. Safeco Insurance Company of Illinois

Sole remaining claim: Breach of the duty to defend, settle and damages under Coverage E of a Safeco HO-6 condominium policy arising out of an underlying HOA lawsuit (Hennepin County Case No. 27-CV-23-10196).
Key requirements:

Draft a complete, court-ready Plaintiff’s Memorandum of Law in Opposition to Defendant’s Motion for Summary Judgment.
Incorporate and respond point-by-point to Safeco’s arguments (no “occurrence,” intentional-acts exclusion, no “damages,” owned-property exclusion, and late notice/prejudice).
Utilize the provided supporting documents (Safeco’s MSJ papers, policy excerpts, HOA complaint, state-court orders, and any Rule 45 subpoena materials).
Apply Minnesota duty-to-defend law (including the “arguably” standard under Meadowbrook and related cases) and Federal Rule of Civil Procedure 56.
Identify and highlight genuine issues of material fact, particularly those supported by documents the HOA has refused to produce.
Maintain a professional, precise, and persuasive legal writing style suitable for filing by a pro se litigant.