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medical expense in the treatment of the injuriea, suffe~~ed physic~l
handicap and his working ability was impaired= the injuries are either
permanent or continuinq in nature and Plafntiff will suffer the losses
and impafrment in the future.
5. The Defendant, AMERICAN EMPLOYERS INSURANCE COMPANY, issued
a policy of liabilfty insurance insurinq the Defendant, DEVITT ADAMS, _
aqainst liability for the neqligent operation of his motor vehicle, and
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the Plaintiff here3n is a thir~ party beneficiary to said policy of
insurance and is entitled to maintain this action under said policy of
insurance as a third party beneficiary thereof.
WHEREFORE, the Plaintiff, OMA JAMES, demands judgment for
damages aqainst the Defendants, ~EVI'~~ ~?I3~i~ and I~MERICAN Fi~iPI.t3YERS
INSURANCE COMPANY, and a trial by jury of all issues_in this action
tryable as of right by a jury. ~
COUNT II
The Plaintiffs realleqe paragraphs 1 through 5 of Count I and
: further allege:
6. As a direct and proximate result of the Defendant's negli-
. gence, the Plaintiff, LUCILLE JAMES, has and will be deprived of her
husband's consortium, services, support, care and the comfort of bi$..
society.
~ WHEREFORE, the Plaintiff, LUCILLE JAMES, demands judgment for
~
,
` damaqes against the Defendants, DEVITT ADAMS and AMERICAN EMPLOYERS
~
~ INSURANCE COMPANY, and further demands trial by jury of all issues in
~ a 'u ~
this action tryable as of right by ~ ry.
~ COUNT III
The Plaintiffs realleqe all of the alleqations of Count I and
incorporate them herein by reference and further allege:
7. That at the time and place of the injury to Plaintiff,
~ OMA JAMES, the Defendant, RITECO DEVELOPMENT CORPORATION, a Florida ~
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corporation, was the owner of the property where the injury occurred ~
and had leased huntinq rights to the Defendant, DEVITT ADAMS, copy of
the lease is attached hereto and by reference made a part hereof as
fully as if set out herein and marked Plaintiffs' Exhibit No. 1, and
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