Debra Susan Dickerson - Page 4




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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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