Rule 14 Third Party Practice

Cross-Claims of Defendant

IN THE CIRCUIT COURT OF COUNTY, ALABAMA

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 Plaintiff 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 , suffered 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 suffered much physical pain and mental anguish and will suffer the same in the future; he specifically sustained

3. As a proximate consequence of the negligence of , was caused to suffer the following injuries and damages:

4. At said time and place, policies of insurance were in effect as insurer covering as driver of the vehicle, through the Defendant, , provides medpay benefits and underinsured motorist benefits 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 insufficient to compensate or satisfy them for their injuries and damages. , by and through their respective mothers, bring this action against for said medpay benefits and the underinsured motorist benefits 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 specifically 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 suffer injuries 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 suffer the same in the future; he/she specifically

9. At said time and place, policies of insurance were in effect with the Defendant, , under which was a covered insured and which provided medpay benefits as well as underinsured motorist benefits.

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 insufficient 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 benefits and underinsured motorist benefits 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 Plaintiff 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, specifically including punitive and/or exemplary damages, plus interest and costs.

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, first class postage prepaid and properly addressed, to the following:

(List counsel for all parties)