The Houston daily post. [volume] (Houston, Tex.) 1886-1903, 1901-12-25
SUITS FOR INSURANCE MONEY.

2s5I, said policies are signed by Daniel A.
lteatd, president, and Thomas H. Greene,
secretary, 'nsirng the plaintiff for the
term OF one year IRON the I'D day OF No
Nember lpO to the I'D day OF Novem-
bcr, llnl, nt noon against all direct loss
anu damage by IRE 10 the amount not eA'
erty;
City Of houston. Texas market house,
ON the twostory brick metal and slate
roof building, with brick and slate roof
tower including the various gas, water
ana electric light fixtures, clock fixtures
ana bell IN tower. occupied a. market
house. clty. hall, council chamber lycenn
han and offices. situated on block No. "a,
between Travis and Milan streets aud
congress aud Preston avenues In the city
Of Houston. Texas; which said policies were
executed by the said defendant acting by
aud through It's lawfully authorized agent,
.. l., Cochran. above named
Thnt at the time Of the Issuing Of s;gl
policies. and at all times from said date 10
the occurrence Of the hre hereinafter meu-
toned, said above described building and
loperty was Of the value Of $4,000 and
plointlh had an Interest In the property IN
sured. as owner thereof to an amount far
exceeding the amount OF Insurance on the
same.
That this plaintiff faithfully complied
with all the terms and conditions OF said
policies to be Kept or performed aud paid
upon execution and delivery to It of said
policies the amount Of $ll2D required by
the said defendant as n premium for In
surfing the above described property dur
Ing the period above named.
Ihnt by the terms Of said above mon
toned policies and payment by plalntih 10
defendant of the above mentioned pre-
MUM on said policies Of insurance the de
ftndant promised to pay the plaintiff the
SAID amount of Insurance above named In
case of loss or damage 10y ire of the build
Ing and property above described during
the period above named.
Ihat ON the oath day of June, 1901,
while the above named policies were in
above lNSrIllpI
tally destroyed and damaged by fire
through no negligence or wrong of this
'rhat the above described property at the
time Of it's destruction by fire was rcasou-
ably worth the sum Of SllG.O0 and that
the total amount Of insurance was only
$4,000 leaving loss 20 plaintiff on said
above described property over and above
the amount for which 1t was insured Of
$4,000 That Ivy the said policies OF In
suraucc the said defendant promised aud
contracted 10 pay the amount Of said pol
icies In case the above mentioned property
and building was destroyed or damaged by
IRE as above alleged within sixty days after
inc plaintiff gave to defendant notice In
writing Of its proof Of loss sustained by
the destruction or damage by fire Of the
ob9y" described property: that the said
plaintiu herein ala on the nth day of
september. 1901, give TO the defendant
herein notc" In writing Of its proof Of
loss sustained by the destruction Of nrc
Of the above described building and prop.
The said defendant The amount Of $500,
the loss. as part Of tho loss sustained bv
II by the destruction by fire on the 2ith
day of June 1901. Of the above described
property. That tho said defendant re-
fused to pay the said amount Of $500 in
direct violation Of its contract as set
forth I'm its policies of insurance made ~
said plaintiff on the 22d day Of November.
1900, as above set forth. aud stul refuses
to pay the amount Of $500 as Il contracted
and stipulated TO do in Its policies OK.
ecutcd on the date above alleged That
the said amount Of $500 is lust due ana
owing to this plaintiff by this defendant,
which this defendant refuses to pay, al
though often requested So to do
Wherefore. the promises considered, This
plaintiff pravs that this defendant he duly
cited according 10 law to answer this peti-
tion. and that upon n hearing hereof hat
II have Judgment for the amount Of $500
above set forth. and for all costs and gen
cral md special relief and as in duty bound
II will ever pray.
Stewart. Stewart & Lockett,
Joe NJ and L. G. Sam
Attorneys for Plaintiff, City If Houston