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PLAINTIFF-COUNTER DEFENDANT
FIFTH DEFENSE
Defendant Martin and Precious Martin did not have any affections to lose when
Defendant Barnett first met Precious Martin.
SIXTH DEFENSE
Defendant Barnett did not seduce Precious Martin. However, Precious Martin did
seduce numerous other women that he had adulterous affairs with over an eight year
period prior to his death.
SEVENTH DEFENSE
Defendant Martin consented to Precious Martin engaging in numerous adulterous
affairs as long as Precious Martin did not divorce her.
EIGHTH DEFENSE
Defendant Martin failed to reasonably attempt to mitigate her damages by not taking
any legal action to prevent any alleged alienation of affection until long after Precious
Martin died.
ANSWER
For answer to Martin's Cross-claims, Barnett denies each and every allegation
therein except as may be expressly admitted herein. With respect thereto:
FACTS
1.
claims.
2.
claims.
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3.
claims.
4.
claims.
5.
claims.
7.
claims.
8.
claims.
9.
claims.
10.
claims.
11.
claims.
12.
claims.
13.
claims.
14.
claims.
15.
claims.
16.
claims.
17.
claims.
18.
claims.
19.
claims.
PRAYER FOR RELIEF
Defendant Barnett denies that Martin is entitled to the relief requested in her Prayer.
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FACTS
1.
3.
On May 11, 2014, Precious Martin died and the life insurance policy vested.
4.
Barnett promptly filed a claim for the insurance proceeds she is due.
5.
Plaintiff initially refused to give Defendant Martin the insurance proceeds, and
asked for a legal explanation as to why she was due the money.
7.
Instead of providing a legal basis for her claim Defendant Martin hired her
current attorney Chuck McRae, who called Plaintiff and threatened it with a bad faith lawsuit
if the money was not paid to his client.
8.
Faced with the threat of a bad faith lawsuit Plaintiff was forced to seek
to interplead the insurance proceeds rather than spend a lot more resources fighting a
frivolous bad faith claim by Defendant Martin.
9.
until after Precious Martin died even though she claims she had been aware of it for several
months.
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funds she is owed, which has resulted in significant damages to Defendant Barnett as a
result of Defendant Martins intentional interference.
13.
interference, and Defendant Martin is liable to Defendant Barnett for the same.
Compensatory damages,
(B)
Punitive damages,
(C)
A judgment for the attorneys' fees and all other costs, interest, and
Defendant Barnett further prays for such other and additional relief as the Court
may deem just and equitable under the circumstances.
RESPECTFULLY SUBMITTED, this 23rd day of December, 2014.
Respectfully submitted,
s/ NICK NORRIS
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CERTIFICATE OF SERVICE
I, Nick Norris, attorney for Defendants/Counter-Plaintiffs, do hereby certify that I
have this day served a true and correct copy of the above and foregoing document via
ECF filing or United States Mail, postage prepaid, on all counsel of record.
s/ Nick Norris
NICK NORRIS
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