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Moss Amended Complaint

Moss Amended Complaint

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Published by John S Keppy

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Published by: John S Keppy on Nov 18, 2013
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11/18/2013

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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
 
 
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5. As a proximate consequence of the negligent or wanton conduct of Defendant James Heath Moss, the Plaintiff's decedent, Sarah Renee Gossett, was fatally injured and caused to die. WHEREFORE, Plaintiff Jerry Ann Schrimsher demands judgment against Defendant James Heath Moss in an amount of damages to be determined by the jury, plus the costs of this action. COUNT TWO 6. Plaintiff Jerry Ann Schrimsher realleges and incorporates by reference all of the factual allegations in the preceding paragraphs. 7. At the time of the collision giving rise to this action, the Plaintiff's decedent, Sarah Renee Gossett, was insured for uninsured and underinsured motorist benefits pursuant to a policy of insurance numbered 945754416 that was issued by Defendant Allstate Insurance Company. 8. Plaintiff's decedent, Sarah Renee Gossett, was fatally injured and caused to die as a result of the negligent or wanton conduct of Defendant James Heath Moss, an uninsured or underinsured motorist. WHEREFORE, Plaintiff Jerry Ann Schrimsher demands judgment against Defendant Allstate Insurance Company in the amount of the policy limits of the policy numbered 945754416,  plus the costs of this action.
THE PLAINTIFF DEMANDS A TRIAL BY STRUCK JURY
 /s/Clint W. Butler
Clint W. Butler (BUT-020) Attorney for Plaintiff
 /s/Roy Braswell
M. Roy Braswell (BRA-085) Attorney for Plaintiff

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