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Case 1:20-bk-12043 Doc 621 Filed 02/24/21 Entered 02/24/2114:52:42 Desc Main <br /> Document Page 13 of 40 <br /> 16. That Plaintiff Billie Jean Cole is and was the wife of Kenneth Cole at the time <br /> of the accident as set forth herein, <br /> 17. That as a direct and proximate result of the actions of the Defendant as set forth <br /> herein, the Plaintiff, Billie Jean Cole, has suffered in the past and will suffer in the future a <br /> loss of society, companionship, consortium, guidance, kindly offices, and advice of her <br /> husband, the PlaintiffKenneth Cole, <br /> PRAYER <br /> WHEREFORE, your Plaintiffs, Kenneth Cole and Billie Jean Cole, each pray for <br /> judgment against the Defendant for compensatory damages; further the Plaintiffs play for <br /> both pre and post judgment interest as allowed by law; further the Plaintiffs pray that they <br /> be awarded their attorney's fees and expenses in connection herewith; and for such other <br /> further and general relief as this Court may deem fit and proper, <br /> PLAINTIFFS DEJAIAND A TRIAL BY JURY ON ALL COUNTS. <br /> KENNETH COL and <br /> BILLIE JEAN COLE,, his wife. <br /> By counsel <br /> muel F. Hanna, Es ire <br /> State Bar No. 1580 <br /> Post Office Box 2311 <br /> Charleston, West Virginia 25328 <br /> (304) 342-2137 <br />