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followinq too close, and by fnattentfon, so that it collided with the
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rear of a motor vehicle beinq driven by Jacquelyn Richardson.
6. As a direct and proximate result of the carelessness
and negliqence of the Defendant, AVA HEAD, as hereinabove mentioned,
the Plaintiff, WILLIB BURKE, was injured in and abaut his body and
extremities, suffered physical and mental pain therefrom, incurred
medical expenae in the treatment of the injuries, suffered phyaical -
handicap and his working ability was impaired; the injuries are either
permanent or continuinq in nature and Plaintiff will suffer the losses
and impairment in the future.
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7. That the Defendant, STONEWALL INSURANCE COMPANY, is a
foreign forporation duly organized and licensed to do business in the
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State of Florida and engaqed in the business of issuing policies of ;
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liability insurance on automobiles in and about the State of Florida.
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8. That prior to the occurrence of the collision aforemen-
tioned, the Defendant, STONEWALL INSURANC$ COMPANY, insured the Defen-
dant, EVA HEAD, against-liability because of bodily injuries sustained
and due to the operation of aaid motor vehicle; that said policy was
written in favor of third persons who might~suffer damages by virtue `
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of the operation of said vehicle, and that by virtue thereof, at the
~iaoment of the occurrence of the accident, the insurance policy inured
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to the benefit of the Plaintiff..
WHEREFORE, Plaintiff demands judgment for damages against
Defendants, EVA SEAD and STONEWALL INSURANCE COMPANY, in an amount in
excess of TWO THOQSAND FIVS HUNDRED DOLLARS ($2,500.00), exclusive of
costs and interest, and further demands trial by jury.
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9. Plaintiff, KATHLEEN BURRE, realleges and adopts Paraqraphs
1 through 7 of Count I and incorporates the same herein by reference.
20. As a direct and proximate result of the aforementioned
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negligence and carelessness of the Defendant, EVA HEAD, the Plaintiff, -
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