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Fill and Sign the Intervening Complaint Mississippi Form

Fill and Sign the Intervening Complaint Mississippi Form

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IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       VS. CIVIL ACTION NO.             INTERVENING COMPLAINT COMES NOW       hereinafter referred to as Intervenor, a foreign corporation authorized to do and doing business in the State of Mississippi as an insurance company, by and through its counsel, and files this its Intervening Complaint, and would show unto the Court the following: 1.       is a corporation incorporated under the laws of the State of Mississippi with its principal place of business in the State of Mississippi. 2.       plaintiff herein, was an employee of the       , Mississippi, on             ,       , and on that date sustained an injury which arose out of and in the course of his employment. 3. Intervenor provided workers' compensation insurance coverage to       on             ,       . 4. Pursuant to such injury, Intervenor has paid, as of             ,       , compensation benefits to plaintiff in the amount of $       and medical services for plaintiff in the amount of $       : said benefits were paid pursuant to the provisions of the Mississippi Workers' Compensation Act. 5. The defendant is liable for the injuries and damages of       all as set forth more fully in the Complaint filed in this cause by plaintiff, a copy of which is attached hereto as Exhibit "A" and made a part hereof by reference as if copied fully herein in words and figures. 6. That       has obtained leave to intervene in this cause pursuant to Rule 24(a), Mississippi Rules of Civil Procedure, and is entitled to reimbursement and exoneration from said defendant pursuant to Miss. Code Ann. Sec. 71 - 3 - 71(1972). WHEREFORE,       , together with plaintiff, demands judgment of and from the defendant in reimbursement and exoneration from the proceeds of any recovery from the defendant herein pursuant to the provisions of Miss. Code Ann. Sec. 71 - 3 - 71(1972), in the total amount necessary to reimburse Intervenor for all amounts paid or to be paid as compensation benefits and medical services rendered to       , together with any and all other sums which Intervenor shall become legally obligated to pay under the provisions of the Mississippi Workers' Compensation Act and to discharge the legal liability of Intervenor, together with all costs which have accrued and which will accrue in this cause. Respectfully submitted,       BY: _______________________________       ATTORNEYS FOR       CERTIFICATE I,       , attorney for       do hereby certify that I have this day mailed, by United States mail, postage prepaid a true and correct copy of the above and foregoing INTERVENING COMPLAINT       , attorney for the       . This the       day of       ,       . ___________________________________      

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