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that at said time and place, the Plaintiff, OMA JAMES, was a lawful
guest of the Defendant, DEVITT ADAMS.
8. That unknown to the Plaintiff and to the Defendant, DEVITT
ADAMS, the Defendant, RITECO DSVELOPMENT CORPORATION, had cut acrosa a
sand road a drainage ditch and had neqligently and carelessly failed to
advise either Plaintiff or Defendant, DEVITT ADAMS, of the locatfon of
said ditch and had failed to post~any type of warnings by way of signs
or markers.
9. As a proximate result of the Defendant, RITECO DEVELOPMENT
CORPORATION'S neqligence, the Defendant, DEVITT ADAMS, neqligently drove
into said ditch as a proximate result of which the Plaintiff, OMA JAMES,
was thrown about witnin the jeep v~hi~2~ driy~n hp the ~~€~:~d~zt, ~
DEVITT ADAMS, and was thrown into the roof-of the jeep injuring the
Plaintiff, OMA JAMES, as heretofore alleged.
WHEREFORS, the Plaintiff, OMA JAMES,~demands judgment for
damages against the Defendants, DEVITT ADAMS, AMERICAN EMPLOYERS
INSURANCE COMPANY and RITECO DEVEIAPMENT CORPORATION, a Florida
corporation, and a trial by jury of all issues in this action tryable
as of right by a jury.
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COUNT IV
I
~ The Plaintiffs reallege all of the alleqations of Count I
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f and Count II and incorporate them herein by reference and further allege: _
10. As a direct and proximate result of the Defendants,
DEVITT ADAMS and RITECO DEVELOPMENT CORPORATION, a Florida corporation,
negligence, LUCILLE JAMES has and will be deprived of her husband's
consortium, services, support, care and the comfort of his society.
WHEREFORE, Plaintiff, LUCILLE JAMES, dema~ds judgment for -
damages against the Defendants, DEVITT A.DAMS, AMERICAN EMPLOYERS
INSURANCE COMPANY and RITECO DEVELOPMENT CORPORATION, a Florida cor-
poration, and further damands trial by jury of all issues in this action
tryable as of right by a jury. ~
. ~ / ~ .
AL FRIER r
Attorney for Plaintiffs
611 Comeau Buildinq
West Palm Beach, Florida 33401
(305) 659-7622
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