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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.
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Last modified: May 25, 2011