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Under the second 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 the types of damages sought.
The third cause of action alleged that Liberty Life was
guilty of conversion by taking various premium payments that were
made by petitioner as a result of the representations or
concealment and suppression practiced by Liberty Life. Under
this 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 the types of damages sought.
The fourth cause of action alleged that Liberty Life was
guilty of a breach of fiduciary duty to petitioner by virtue of
committing the acts described in the amended complaint. Under
this 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 the types of damages sought.
In May 1995, petitioner settled her action against Liberty
Life for $40,000. The settlement was memorialized by a release,
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Last modified: May 25, 2011