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Case 1:20-bk-12043 Doc 621 Filed 0 /24Page Entered <br /> 002/24/21 14:52:42 Desc Main <br /> Document <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 Plaintiff Kenneth 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 pray for <br /> both pre and post judgment interest as allowed by law; further the Plaintiffs pray that they <br /> i <br /> be awarded their attorney's fees and expenses in connection herewith; and for such other <br /> g <br /> s <br /> further and general relief as this Court may deem fit and proper. <br /> r <br /> PLAINTIFFS DEMAND A TRIAL BY JURY ON ALL COUNTS. � <br /> i <br /> r t <br /> KENNETH COLE and 1 <br /> BILLIE JEAN COLE, his wife. t <br /> By counsel <br /> a <br /> 41re <br /> muel F. Hanna, E <br /> State Bar No. 1580 � <br /> Post Office Box 2311 <br /> Charleston, West Virginia 25328 1 <br /> (304) 342-2137 1 <br /> 3y <br /> f <br /> f <br /> S <br />