Fill and Sign the Al Defendant 497295742 Form

IN THE CIRCUIT COURT OF __________ COUNTY, ALABAMA _________________ * * Plaintif, * * VS. * CIVIL ACTION NO.: * _________________ * CV-_______________ * Defendant. * CROSS-CLAIMS OF DEFENDANT COMES NOW___________________, as ______________________________ and next friend of ________________________, a minor, and makes these, Cross-claims against the Defendant named in the original Complaint as “____________________________": COUNT ONE 1. On or about ___________________, on ___________ Road near the intersection of ____________________________ in _____________County, Alabama, _________________________, the driver of an automobile insured by the Plaintif in this action, _________________________________ (insurance company), negligently caused or allowed said motor vehicle to collide with the vehicle being operated by ______________________________ and occupied by _______________________________. 2. As a proximate consequence of the negligence of _____________________, _________________________ sufered injuries to many parts of his body; his injuries are permanent; he has incurred medical expenses and will incur future medical expenses, and he has sufered much physical pain and mental anguish and will sufer the same in the future; he specifcally sustained [list specifc injuries and damages]. 3. As a proximate consequence of the negligence of __________________, ________________________________ Insured, _____________________________ was caused to sufer the following injures and damages: [list injuries and damages]. 4. At said time and place, policies of insurance were in efect as insurer covering _______________________ as driver of the vehicle, through the Defendant, ________________________, provides medpay benefts and underinsured motorist benefts for ______________________________________. 5. _____________________________________________, by and through their respective mothers and next friends, allege that the liability insurance coverage available to them through ______________________________’s insurance, with ______________________________________, is inadequate or insufcient to compensate or satisfy them for their injuries and damages. ________________________________________, by and through their respective mothers, bring this action against _________________________________ for said medpay benefts and the underinsured motorist benefts applicable and available through ____________________ and the covered vehicle. WHEREFORE, ______________________________________ demand judgment against the Defendant, ______________________________ Company, in excess of the jurisdictional limits of this court plus interest and costs. COUNT TWO 6. ____________________________________ adopt and reallege Count One with the exception that they substitute the words "wantonly" for "negligently" and "wantonness" for "negligence”. WHEREFORE, ______________________________________ demand judgment against the Defendant, ______________________________ Company, in excess of the jurisdictional limits of this court specifcally including punitive and/or exemplary damages, plus interest and costs. COUNT THREE 7. _______________________ adopts and realleges Counts One and Two. 8. As a proximate consequence of the negligence of ___________________, ______________________, was caused to sufer injures to many parts of his body; he/she has incurred medical expenses and will incur future medical expenses; he/she has incurred much physical pain and mental anguish and will sufer the same in the future; he/she specifcally [list specifc injuries and damages]. 9. At said time and place, policies of insurance were in efect with the Defendant, _________________________________, under which _______________ was a covered insured and which provided medpay benefts as well as underinsured motorist benefts. 10. ________________ alleges by and through his mother and next friend, ______________, that the liability insurance coverage available to _______________'s insurance with ______________________________ Insurance Company, is inadequate or insufcient to compensate or satisfy him/her for his/her injuries and damages. ______________________, by and through his mother and next friend ________________, brings this action against the Defendant, ________________________________________ for the medpay benefts and underinsured motorist benefts pursuant available to him under said policies of Insurance. WHEREFORE, _____________________ demands judgment against the Defendant, ______________________________________, in excess of the jurisdictional limits of this Court, plus interest and costs. COUNT FOUR 11. __________________________ adopts and realleges Counts One and Two, and adopts and realleges (Count Three with the exception that Plaintif substitutes the words “wantonly" for "negligently” and "wantonness" for the word "negligence". WHEREFORE, _______________________ demands judgment against the Defendant, _______________________________________ Company, in excess of the jurisdictional limits of this Court, specifcally including punitive and/or exemplary damages, plus interest and costs. __________________________________ OF COUNSEL: ________________________ CERTIFICATE OF SERVICE I certify that I have on this _____ day of __________, ________, served a copy of the foregoing by mailing same by U. S. Mail, frst class postage prepaid and properly addressed, to the following: (List counsel for all parties) _________________________________________