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IN THE CIRCUIT COURT OF THE NINETEENTH
JUDICIAL CIRCUIT, IN AND FOR SAINT
LUCIE COUNTY, FLORIDA.
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CASE NO. 80-24+~ -cA
GEORGE PRICE,
Plaintiff, -
vs.
LUMBERMENS MUTUAL CASUALTY
COMPANY,
Defendant.
JOINT STIPULATION FOR FIRST AMENDMENT TO ANSWER
The parties hereto, by and through their undersigned attorneys,
jointly move the Honorable Court herein pursuant to Florida Rule of
Civil Procedure Rule 1.190 (c) for leave permitting the Defendant
to file this its First Amendment to the Answer herein by the addition
of Paragraph "8" as follows:
8. For a third affirmative defense Defendant would show
that Plaintiff unreasonably delayed in permitting this
Defendant to seek the salvage value of the vehicle herein
sued upon and tha by virtue of such unreasonable delay
the value of the salvage has been substantially reduced,
thereby warranting an offset against whatever amounts
Plaintiff may be entitled to recover herein on the property
damage claim in correspondence with such reduction
in value.
Further, the above parties pray that such Amendment shall be
effective immediately upon entry of an order approving same and would
jointly represent that Plaintiff retains all rights and remedies with
respect to such amendment as may be available to Plainti under the
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Florida Rules of Civil Procedure.
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- BORNE WALKER O'QUINN, ESQ. JAMES T. LKER, ES _
P.O. Box 4341 .O. Bo 3779
Ft. Pierce, FL 33454 Ft. rce, FL 33454
Attorney for Plaintiff Attorney for Defendant
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