§ FORM 12 THIRD PARTY COMPLAINT

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FORM 12. THIRD PARTY COMPLAINT

    [Caption and signature block as in Form 1]

    1. On _______, third party defendant issued an insurance policy (the “Policy”) indemnifying third party plaintiff against negligence claims arising from the use of third party plaintiff's automobile.

    2. Plaintiff's complaint in this action alleges that on _______, while the Policy was in force, third party plaintiff negligently drove his automobile causing an accident with plaintiff. The complaint, a copy of which is attached hereto as Exhibit A, seeks general and special damages from third party plaintiff.

    3. Third party plaintiff demanded indemnification under the Policy for plaintiff's claims, but third party defendant refused the demand.

    4. Based upon the foregoing facts, third party defendant is liable to third party plaintiff for all or part of what plaintiff may recover from third party plaintiff.

    Wherefore, third party plaintiff requests judgment against third party defendant for any amount recovered by plaintiff against third party plaintiff.