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IN THS CIRCUIT COURT OF THS NINETEENTH
JUDICIAL CIRCUIT OF FLORIDA, IN AND FOA
ST. LUCIB COUNTY.
CASB NO. 77-92 CA ~
OMA JAMES and LUCILLS JAMES, )
his wife,
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Plaintiffs,
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vs •
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DEVITT ADAMS, AMERICAN EMPLOYERS
INSURANC$ COMPANY and RZT8C0 )
DEVELOPMBNT COR~ORATION, a Florida ~
corporation, )
Defendants. )
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~ AMENDED COMPLAINT
AND DEMAND FOR JURY TRIAL
The Plaintiffs, OMA JAMES and LUCILLE JAMES, his wife, sue
the Defendants, DEVITT ADAMS, AMERICAN EMPLOYERS,INSURANCE COMPANY and
RITECO DEVELOPMENT CORPORATION, a Florida corporation, and allege:
COUNT I
l. This is an action for damages which arose in Okeechobee
County, Florida, and the amount in controversy is in excess of $10,000.
2. On or about January 3, 197'6, the Defendant, DEVITT ADAMS,
owned and operated a jeep motor vehicle on private property in Okeechobee
County, Florida, approximately five to seven miles north of Fort Drum,
Florida, and west of Highway 441.
3. At the time and place the Defendant, DEVITT ADAMS, did so
carelessly and negligently operate the jeep vehicle in which the Plain-
tiff, OMA JAMES, was a passenger so as to cause the vehicle to ~strike
some object or qo into some ditch; the exact nature of which is unknown
to the Plaintiff and is better known to the Defendant.
4. As a proximate result of Defendant's neqligence, the
Plaintiff, OMA JAMES, was thrown about within the jeep vehicle and was
thrown into the roof of the jeep, injurinq the Plaintiff OMA JAMES as
hereinafter more specifically alleged. The Plaintiff was injured in
and about his body and extremities, suffered pain therefrom, incurred
~ 800K ~7U PACE +
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