IN THE CIRCUIT COURT OF LIMESTONE COUNTY, ALABAMA JERRY ANN SCHRIMSHER, ) Administrator Ad Litem of the Estate of ) SARAH RENEE GOSSETT, ) Deceased, ) ) Plaintiff, ) ) vs. ) CV-2011-900111 ) JAMES HEATH MOSS and ) ALLSTATE INSURANCE COMPANY, ) ) Defendants. )
FIRST AMENDED COMPLAINT
COMES NOW the Plaintiff in the above-styled cause and files this as her First Amended Complaint: COUNT ONE 1. Plaintiff Jerry Ann Schrimsher is the Administrator Ad Litem of the Estate of Sarah Renee Gossett, deceased. 2. On or about April 25, 2011, on Lucas Ferry Road, in Limestone County, Alabama, Defendant James Heath Moss negligently or wantonly caused or allowed a motor vehicle to collide with a motor vehicle occupied by the Plaintiff's decedent, Sarah Renee Gossett. 3. At and before the time of the collision giving rise to this action, Defendant James Heath Moss acted willfully, maliciously, beyond his authority, or under a mistaken interpretation of the law. 4. Plaintiff Jerry Ann Schrimsher brings this action against Defendant James Heath Moss in his individual and personal capacity.
ELECTRONICALLY FILED6/9/2011 5:46 PMCV-2011-900111.00CIRCUIT COURT OFLIMESTONE COUNTY, ALABAMACHARLES PAGE, JR., CLERK