- 4 - The amended complaint included 4 causes of action. The first cause of action alleged that the representations made by Liberty Life with respect to the insurance policies were made intentionally, recklessly, or negligently with the intent that petitioner would rely on such representations. The first cause of action also alleged that these representations were part of a pattern and practice encouraged and sanctioned by Liberty Life. Finally, the first cause of action alleged, summarily, that petitioner had suffered “mental anguish”. Under the first cause of action, petitioner sought recovery of an unspecified sum for actual damages, general damages, punitive damages, and such other damages as authorized by Alabama law. Petitioner did not allege how such damages should be allocated among either the types of damages sought or the claims made in the first cause of action. The second cause of action alleged that Liberty Life wrongfully concealed and suppressed from petitioner the true nature of the insurance policies in that Liberty Life never revealed to petitioner the fact that coverage for payment of benefits was limited to only one policy of insurance. The second cause of action further alleged that Liberty Life wrongfully concealed and suppressed from petitioner the true nature of the pattern and practice in which Liberty Life was engaged.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011