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Case 1:11-cv-00307-N Document 4

Filed 06/15/11 Page 1 of 3

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ALABAMA DELANEY DEVELOPMENT, INC. , and YESTER OAKS APARTMENTS * * CIVIL ACTION NO. 11-307 * * VERSUS * JUDGE: * ILLINOIS UNION INSURANCE COMPANY * MAGISTRATE: ****************************************************************************** PLAINTIFFS FIRST SUPPLEMENTAL AND AMENDING COMPLAINT NOW INTO COURT, through undersigned counsel, come plaintiffs, Delaney Development, Inc. and Yester Oaks Apartments, who file this First Supplemental and Amending Complaint as follows: 1. Plaintiffs re-allege and re-aver all allegations, assertions and demands made in its original Complaint, previously filed on June 10, 2011, as if copied herein in extenso. 2. Plaintiffs amend its opening paragraph of Plaintiffs original Complaint so that the

Case 1:11-cv-00307-N Document 4

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opening paragraph reads as follows: NOW INTO COURT, through undersigned counsel, comes plaintiffs, Delaney Development, Inc. and Cabana Apartments, who respectfully represent as follows in this Complaint for Damages:

3. Plaintiffs amend Paragraph I of Plaintiffs original Complaint to more fully clarify plaintiffs, and so that Paragraph I reads as follows: I. Made plaintiffs herein are: DELANEY DEVELOPMENT, INC., a corporation organized under the laws of Alabama and with its principal place of business in Alabama; and YESTER OAKS APARTMENTS, a corporation organized under the laws of Alabama and with its principal place of business in Alabama.

4. Plaintiffs re-allege and re-aver each and every allegation in the prayer of his original Complaint as if fully copied herein. WHEREFORE, plaintiffs herein pray that its First Supplemental and Amending Complaint be deemed good, valid, and sufficient, and after due proceedings had, there be judgment rendered herein in its favor. Plaintiffs further pray that Illinois Union Insurance Company be served with a copy of the original Complaint as well as this First Supplemental and Amending Complaint and be duly cited to appear and answer the same, and that after expiration of all legal delays and due proceedings, there be judgment rendered in favor of plaintiffs and against defendant, in an amount that will fully compensate plaintiffs for its damages pursuant to the evidence and in accordance with 2

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the law and for penalties and attorneys fees; all sums with legal interest thereon from the date of judicial demand until fully paid, for all costs of these proceedings, and for all general and equitable relief.

Respectfully submitted, /s/C. Bennett Long__________________ C. Bennett Long (Bar No. LON0046 ) 116 East I-65 Service Road North, Ste. A Mobile, AL 36607 Telephone: (251) 639-4100 Facsimile: (251) 476-1042 Email: bennett@lwpc.com ATTORNEY FOR PLAINTIFFS

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 15th day of June, 2011, I electronically filed the foregoing with the Clerk of Courts ECF system, which will automatically send notice to all counsel of record.

/s/C. Bennett Long__________________ C. Bennett Long