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Football Manager 2020 Fit girl Repack, your way. every choice counts in soccer manager 2020 with new functions and polished recreation mechanics worthwhile planning and development like in no way earlier than, empowering managers to develop and refine each your club’s and your personal precise identity.

Stroll down the tunnel to a dwelling, breathing football global with you on the very heart of it. around right here, your opinion matters!

This is a world that rewards making plans and know-how but, in contrast to other video games, there’s no pre-defined finishing or script to observe – simply endless possibilities and possibilities. every membership has a tale to tell and it’s down to you to create it.

They say football is a game of dreams. nicely, managers are a special breed of dreamers.They don’t see problems, simplest opportunities: the chance to prove themselves in opposition to the first-class in the global, to expand and instil a brand new footballing philosophy, to nurture skills through the ranks, to raise the club to greater heights and stop the look forward to silverware.

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  • Base yourself in 50 of the most important footballing countries international
  • Oversee a brand new generation of success at one of 2,500 golf equipment at every level
  • Sign the fine and mildew the destiny – scout greater than 500,000 actual players and team of workers
  • Create your tactical imaginative and prescient and convey it to existence at the schooling pitch
  • Kick every ball with our most immersive and smartest fit engine to this point.

Improvement centre:take full control of your youngsters crew operations in a new all-encompassing hub. nurture your young stars from the instant they arrive at your membership and thru the teenagers ranks until they’re geared up for first-team motion.

Membership imaginative and prescient:develop a culture, work with the board to achieve ongoing goals and plot a path in your club to development in seasons to come back. membership imaginative and prescient goes a long way past the boardroom; impacting on transfers, playing style and competition expectations as you appearance to bolster your membership’s identification and meet the multi-year milestones.

Playing time pathway:an entire new way to outline a player’s standing for your squad. build in modern and destiny gambling time across the period of a settlement, defining a clean pathway from fringe participant to star player and the whole thing in among.

Backroom personnel:new roles, advice and interaction make your personnel more worried and vital than ever. more collaboration across more areas brings the sport toward the shape of a actual-existence backroom crew.
photo improvements

Redesigned participant and supervisor fashions, stepped forward lighting and overhauled pitch visuals combine to create the maximum realistic and first-rate-searching healthy revel in to this point.

Football Manager 2020 Torrent Download

Football manager 2020 download full version is the sixteenth precept part of the damage hit association of soccer directors, that is regulated via sports interactive studio. as it become the scenario with the prior portions of the cycle, the appearance of this technology became treated via sega.

Football Manager 2020 ocean of games:We start with the aid of choosing one of the 2500 golf equipment from 50 international locations that we’d need to turn into an administrator of. there is as but nothing left for us to do but to assume liability for each part of the group’s running. all through the game we buy and promote players (there are over a massive part of a million proper names in the game), we address the players’ preparation plan, and we likewise set the strategies for the following video games. fits are an ordeal of our administrative abilties. while deciding, we should consider now not simply our membership’s file stability (on account that the monetary backing is constrained), yet moreover relations with the media and fans, who don’t generally need to just like the choices we make.

Football Manager 2020 download PC game enables you to play both by myself and in multiplayer mode over the net.

Football Manager 2020 download zip follows within the strides of the beyond portions of the arrangement to the quantity the visible depiction is concerned. while matches are performed in a 3-dimensional circumstance, greater often than no longer we watch an unpredictable interface, which accommodates of home windows containing a wide range of information, measurements, outlines and tables.

Football Manager 2020 Fitgirl Repack To the pc rendition of football supervisor 2020 torrent download is protected complimentary its rearranged form, that is soccer supervisor contact 2020.

Football Manager 2020 review

Download Football Manager 2020 This time last 12 months we, like many others, declared soccer manager 2019 one of the nice instalments in the lengthy-strolling series. large strides had been taken, particularly in areas that were neglected for too lengthy, and the sport felt as welcoming to new gamers as it became nourishing for those who have performed the collection for nigh-on two decades. getting a game so right brings with it demanding situations though.

Install Football Manager 2020 the brains at sports interactive have always strived to pay attention to community comments and most of the annual upgrades come directly from the returned-and-forth with veteran members in their boards. it’s a dynamic that has worked properly for years and ensures the game is carefully tested by means of folks who hold a deep ardour for the collection. critics robotically ask why the community are the ones charged with testing football supervisor while it’s in its beta kingdom, but it’s comprehensible given the complexity of the sport. fFootball Manager 2020 is not an clean sport to choose up and whizz thru – at the least now not if you’re a micromanagement type who likes their fingerprints to be felt throughout their club. if you’re after something extra similar to the old championship managers then soccer manager contact – which is likewise available for smartphones and switch – may be greater to your taste. we, but, opt to depart no stone unturned and that’s the cause that simply getting via the primary few days of a season can take hours. so what’s inspired us to date?

Fitgirl Football Manager 2020 the development centre is the feature to be able to stand out most to players of the collection – subsequently a tab housing the whole lot you may likely need to understand approximately your younger gamers. kids improvement has constantly been at the middle of the series and the joys of being informed you’ve been fortunate enough to usher in a ‘golden era’ in no way receives antique it’s a smart circulate then, that sports interactive have brought a news item providing you with a indistinct appraisal of the teenagers crew players heading into the club, with out telling you their names or attributes.

igg games Football Manager 2020 makes the yearly young people consumption experience even more exciting than it already is. smarter still is the dynamic date of the teens intake. in which once it turned into a set day for the whole state, and absolutely a one-day-in-the-yr occasion, now it movements and shifts. it not best makes the identity of your membership feel more true to life, it approach exploitative managers used to hoovering up the fine skills on the equal day every 12 months may additionally battle to accomplish that.

Football Manager 2020  Repack beyond that, the improvement centre is a fantastic location to keep tabs on every body at the club not currently on your first group and from education to their character improvement it’s simpler than ever to offer that 5-star prospect the steerage they need.

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The Insurance Society of New York

The Insurance Society of New York
The Insurance Society of New York

The subject of insurance forms is such an exceedingly broad one, that it will be impossible in an address such as this to do more than touch upon it in a general way, and direct attention to some of the more important forms, which, although in general use, may possess features which are not fully understood.
The best form, whether viewed from the standpoint of the insurance company or the insured, is a fair form, one which expresses in clear, unambiguous language the mutual intention of the parties, and affords no cause for surprise on the part of either, after a loss has occurred. But the prepara¬ tion of such a form is not always an easy task, and it is right at this point that the ability of the broker and the underwriter come into play.
A distinguished Englishman declared that the English Constitution was the greatest production that had ever been conceived by the brain of man, but it was subjected to the most scathing criticism and violent assaults by Bentham, the great subversive critic of English law. Twenty-five years ago the New York Standard Policy was prepared by the best legal and lay talent in the insurance, world, and the greatest care was taken to present not only a reasonable and fair form of contract between the insurer and the insured, but one which could be easily read and understood.
While no such extravagant claims have been made for the Standard Policy as were made for the “Matchless Con-maximum of loss collection with a minimum of co-insurance or other resistance than a present day broker, he has not yet been discovered.
The ornate policies in use thirty years ago, with no uniformity in conditions, with their classification of hazards which no one could understand and their fine print which few could read, have given way to plainly printed uniform Standard Policies with materially simplified conditions. But the written portion of the insurance contract owing to our commercial and industrial growth, instead of becoming more simple, has taken exactly the opposite direction, and we now have covering under a single policy or set of policies, the entire property of a coal and mining company, the breweries, public service or traction lines of a whole city and the fixed property, rolling stock and common carrier liability of an entire railroad system involving millions of dollars and con¬ taining items numbering into the thousands. This forcibly illustrates the evolution of the policy form since the issue of the first fire insurance contract by an American company one hundred and sixty years ago, in favor of a gentleman bearing the familiar name of John Smith, covering
“500 £ on his dwelling house on the east side of King Street, between Mulberry and Sassafras, 30 feet front, 40 feet deep, brick, 9-inch party walls, three stories in height, plas¬ tered partitions, open newel bracket stairs, pent houses with board ceilings, garrets finished, three stories, painted brick kitchen, two stories in height, 15 feet 9 inches front, 19 feet 6 inches deep, dresser, shelves, wainscot closet fronts, shingling 1-5 worn.”
It will be observed that in the matter of verbiage this primitive form rivals some of our present day household furniture forms and all will agree that this particular dwelling might have been covered just as effectually and identified quite as easily without such an elaborate description.
Any one who has an insurable interest in property should be permitted to have any form of contract that he is willing to pay for, provided it is not contrary to law or against public policy, and judging from a contract of insurance issued by a certain office not long ago the insuring public apparently has no difficulty in securing any kind of a policy it may desire at any price it may be willing to pay. The contract in ques¬ tion was one for £20,000, covering stock against loss from any cause, except theft on the part of employes, anywhere in the Western Hemisphere, on land or water, without any con¬ ditions, restrictions or limitations whatsoever, written at less than one-half the Exchange rate in the insured’s place of business. An insurance agent upon being asked whether he thought it was good, said that if the company was anywhere near as good as the form, it was all that could be desired, but vouchsafed the opinion that it looked altogether too good to be good.

The Insurance Society of New York
The Insurance Society of New York

In these days we frequently find concentrated within the walls of a single structure one set of fire insurance policies covering on building, another on leasehold interest, another on rents or rental value—and in addition to this, policies for various tenants covering stock, fixtures, improvements, profits and use and occupancy, subject to the 100% average or co-insurance clause, to say nothing of steam boiler, casualty and liability insurance, thereby entirely eliminating the ele¬ ment of personal risk on the part of the owners, and produc¬ ing a situation which will account in some measure for the 17,000 annual fire alarms and $15,000,000 fire loss in New York City; $230,000,000 annual fire loss in the country at large, and for the constantly increasing percentage of cases where there are two or more fires in the same building and two or more claims from the same claimant.
The most common and perhaps least understood phrase found in policies of fire insurance is what is known as the “Commission Clause,” which reads “his own or held by him in trust or on commission or sold but not delivered” or “re¬ moved.” This clause in one form or another has been in use for many years, and it was originally the impression of un¬ derwriters that owing to the personal nature of the insurance contract a policy thus worded would simply cover the prop¬ erty of the insured and his interest in the property of others, such as advances and storage charges, but the courts have disabused their minds of any such narrow interpretation and have placed such a liberal construction upon the words “held in trust” that they may be justly regarded as among the broadest in the insurance language and scarcely less com¬ prehensive than the familiar term “for account of whom it may concern”; in fact, the principles controlling one phrase are similar to those governing the other.
It has been held that whether a merchant or bailee has assumed responsibility, or agreed to keep the property cov¬ ered or whether he is legally liable or not, if his policies contain the words “held in trust,” the owner may, after a fire, by merely ratifying the insurance of the bailee, appro¬ priate that for which he paid nothing whatever and may file proofs and bring suit in his own name against the bailee’s insurers. Nor is this all, for in some jurisdictions, if the bailee fails to include the loss on property of the bailor in his claim against his insurers, or if he does include it and the amount of insurance collectible is less than the total loss, the bailee may not first reimburse himself for the loss on his own goods and hold the balance in trust for the owners, but must prorate the amount actually collected with those own¬ ers who may have adopted the insurance, although, if he has a lien on any of the goods for charges or advances, this may be deducted from the proportion of insurance money due such owners The phrase “for account of whom it may concern” was formerly confined almost entirely to marine insurance, but in recent years there has been an increasing tendency to intro¬ duce it into policies of fire insurance.
All authorities are agreed that the interests protected by a policy containing these words must have been within the contemplation of him who took out the policy at the time it was issued. It is not necessary that he should have in¬ tended it for the benefit of some then known and particular individuals, but it would include such classes of persons as were intended to be included and who these were may be shown by parol. The owners or others intended to be cov¬ ered may ratify the insurance after a loss and take the bene¬ fit of it, though ignorant of its existence at the time of the issuance of the policy, just the same as under the term “held in trust.”
The words “for account of whom it may concern” are not limited in their protection to those persons who were concerned at the time the insurance was taken out, but will protect those having an insurable interest and who are con¬ cerned at the time when the loss occurs. They will cover the interest of a subsequent purchaser of a part or the whole of the property and supersede the alienation clause of the policy (U. S. S. C.), Hagan and Martin vs. Scottish Union and National Ins. Co., 32 Ins. Law Journal, p. 47; 186 U. S. 423).
A contract of insurance written in the name of “John Doe & Co. for account of whom it may concern” should contain a clause reading “Loss, if any, to be adjusted with and payable to John Doe & Co.,” not “loss, if any, payable to them” or “loss, if any, payable to the assured,” as forms sometimes read.
Policies are frequently written in the name of a bailee covering “On merchandise, his own and on the property of others for which he is responsible,” or “for which he may be liable”—and it has been held that’the effect of these words is to limit the liability of the insurer to the loss on the assured’s own goods and to his legal liability for loss on goods belonging to others, but the words “for which they are or may be liable” have been passed upon by the Supreme Court of Illinois, and they have been given an entirely dif¬ ferent interpretation. That tribunal in the case of The Home Insurance Company vs. Peoria & Pekin Union Railway Co. (28 Insurance Law Journal, p. 289; 178 Ills. 64) decided that the words quoted were merely descriptive of the cars to be insured; that the word “liable” as used in the policy did not signify a perfected or fixed legal liability, but rather a con¬ dition out of which a legal liability might arise.
As illustrative of its position the court said that an assignor of a negotiable note may, with no incorrectness of speech, be said to be liable upon his assignment obligation is not an absolute fixed legal liability but is con¬ tingent upon the financial condition of the maker; and ac¬ cordingly held that the insurance company was liable for loss on all the cars in the possession of the railroad company, notwithstanding the fact that the latter was not legally liable to the owners.
In view of the exceedingly broad construction which the courts have placed upon the time honored and familiar phrases to which reference has been made, it is important for the party insured, whether it be a railroad or other transportation company, a warehouseman, a laundryman, a tailor, a com¬ mission merchant or other bailee, to determine before the fire whether he desires the insurance to be so broad in its cover as to embrace not only his own property and interest, but also the property of everybody else which may happen to be in his custody; if so, he should be careful to insure for a sufficiently large amount to meet all possible co-insurance conditions,, and if he wishes to make sure of being fully reimbursed for his own loss, his only safe course is to insure for the full value of all the property in his possession.
At this point the inquiry which naturally presents itself is, how should a policy be written if a merchant, warehouse¬ man or other bailee desires to protect his own interest but not the interest of any one else? The following form is suggested: “On merchandise his own, and on his interest in and on his legal liability for property held by him in trust or on commission or on joint account with others, or sold but not removed, or on storage or for repairs, while con¬ tained, etc.” This will, it is believed, limit the operation of co-insurance conditions and at the same time prevent the owners from adopting, appropriating or helping themselves to the bailee’s insurance, for which they pay nothing and to which they are not equitably entitled.
Many of the household furniture forms now in use, in addition to embracing almost every conceivable kind of per¬ sonal property except that specifically prohibited by the pol¬ icy conditions, are also made to cover similar property be¬ longing to any member of the family or household, visitors, guests and servants.
This form would seem to indicate considerable ingenu¬ ity on the part of the broker, broad liberality on the part of the insurance company and commendable generosity on the part of the insured, and the latter would probably feel more than compensated by being able to reimburse his guest for any fire damage he might sustain while enjoying his hospi¬ tality, but the amount of insurance carried under such a form should anticipate the possibility of his having a number of guests at one time and a corresponding increase in the value at risk.
It must be borne in mind that in localities where co- insurance conditions prevail the value of property belonging

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Overview of Age of Empires II Definitive Edition Fitgirl Repack 2019:-After a long wait this game is finally released and we are here to show you and give you a review about Age of Empires II Definitive Edition .This game is Published by ova games and developed under the banner of skidrow once you download Age of Empires II Definitive Edition then there is no hard method to Install Age of Empires II Definitive Edition on PC without any error .To avoid any error we recommend you to watch game installation video.

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Companies: Ocean of games, igg games
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Original Size: 17.7 GB
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Age of Empires II Definitive Edition celebrates the 20 th anniversary of one of the maximum popular approach video games ever with lovely 4k extremely hd pix, a new and completely remastered soundtrack, and emblem-new content material, “the closing khans” with three new campaigns and four new civilizations.

Discover all the authentic campaigns like never earlier than in addition to the pleasant-selling expansions, spanning over two hundred hours of gameplay and 1,000 years of human history. head on-line to assignment different players with 35 exceptional civilizations to your quest for global domination for the duration of the ages.

Choose your path to greatness with this definitive remaster to one of the most loved method games of all time.

These days, we’re pleased to announce that age of empires ii: definitive version can be coming to the microsoft keep, xbox recreation pass for pc (beta) and final, and steam on november 14, 2019!

For all you age ii players eagerly searching ahead to the arrival of the definitive version, you can additionally pre-order the game beginning nowadays! you’ll be able to experience all of the capabilities—along with pass play along with your friends, 4 emblem-new civilizations, 3 new campaigns, and a delivery ship complete of recreation enhancements—proper on day one, so be sure to free up your replica nowadays:

Our goal is to make the great feasible model of age ii that we can, operating proper alongside our network. so while age ii de’s release is only a few months away, you can sign on to participate inside the age ii de beta right now—visit ageofempires.com/insiders to sign up for the age insider software – and help us music and refine age ii even in addition. you’ll also have a hazard to participate in destiny beta opportunities, so sign on!

Age of Empires II Definitive Edition is a actual-time strategy video game developed by using forgotten empires and published by xbox game studios. it’s miles a definitive remaster of the authentic sport age of empires ii: the age of kings, celebrating the 20 th anniversary of the unique. it capabilities substantially progressed visuals, helps 4k resolution, a new unmarried participant campaign known as the last khans and four new civilisations. it also includes all previous expansions from the unique and hd version. it became released on 14 november 2019.

the core gameplay factors are shared closely with the authentic however the definitive edition builds upon it. the remaster consists of new 4k pics, new stepped forward visuals for troops and buildings, the capacity to zoom in and similarly out and a brand new spectator mode. it also features a brand new campaign known as the the remaining khans and 4 new civilisations: bulgarians, cumans, lithuanians and tatars. it is also all previous expansions from the original (the conquerors) and hd version (the forgotten, the african kingdoms, upward push of the rajas).

bert beeckman (left) and adam isgreen (proper) at e3 2019. isgreen is the innovative director on definitive edition and beeckman is the co-founding father of forgotten empires
gamers can pick out between the unique ai, which had to cheat to be competitive, the hd version ai, which is an ai that became added alongside the hd edition of the sport and the brand new one that is advanced enough to no longer require any cheating. whilst the vintage and new ais had been pitted in opposition to each other in a test, the new one effortlessly defeated the old one unit pathfinding development is also anticipated

Age of empires 2 is being wheeled out again, not pretty new, but truly improved. it wears its two decades properly, but the years are nevertheless there, hidden under polish and new art and myriad tweaks. the definitive edition wavers among remaster and remake, updating almost the whole lot, from the art to the ai, in addition to including a trio of recent campaigns and four greater civilisations, but reverence for the original means that the adjustments, even though extensive and welcome, are truly constrained.

An awful lot of that reverence is justified, and what made age of empires 2 stand out at a time when there has been no dearth of terrific real-time method video games holds it in accurate stead two decades on. even though its objectives had been just like its predecessor’s, the try and combine real-time approach with town building and sid meir’s civilization became plenty more a hit the second time around. it changed into additionally without a doubt a higher, richer strategy game.

The definitive edition makes it less complicated to realize why it had the effect it did. ultimately, in 2019, age of empires 2 lets you inform your villagers to mechanically reseed farms! no more coming back from a struggle to locate the fields fallow and my villagers twiddling their thumbs. this is probably the most interesting alternate for me, the most boring guy in the international. it without a doubt does shop a whole lot of complications, even though, and is one of several ways the new version offers you extra manipulate whilst still reducing down on unnecessary micromanagement.

Exceptional of existence enhancements may not sound like a great deal of a headline enchantment, but age of empires 2 needed them just as a good deal as the brand new campaigns and the visual overhaul. queuing up special gadgets and improvements, being able to drag and choose armies without grabbing villagers via mistake, queuing commands—most of what i wished the first age of empires: definitive edition blanketed has been brought right here. the result is a extra steady pace that leaves you with greater time to spend increasing your civilisation and commanding armies.

The ones are areas in which it is largely commercial enterprise as normal. you begin with a metropolis centre and a handful of villagers, gather sources, plonk down homes and make bigger until you’ve got a massive navy and an excellent fortified town. across the campaigns and skirmishes, this familiar routine is repeated, tweaked and occasionally subverted, but at the same time as age of empires 2’s contemporary curators have up to date plenty around it, the instant-to-second civilisation and navy management has been preserved.

Not like the first age of empires, massive armies are extra workable thanks to formations and improved pathfinding. they try to take the most green route, and whilst units can nevertheless get caught whilst they’re blocked by means of their pals, you could switch formations to provide them extra room to move. after they get into melee, however, formations disintegrate and end up large brawls in which every inch of space is filled with warriors hacking away at every different.

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Age of Empires II Definitive Edition celebrates the 20th anniversary of one of the maximum popular method video video games ever with lovely 4k extraordinarily hd photographs, a brand new and completely remastered soundtrack, and logo-new content material material, “the final khans” with 3 new campaigns and 4 new civilizations.

Find out all of the genuine campaigns like never in advance than further to the first-class-selling expansions, spanning over hundred hours of gameplay and 1,000 years of human records. head on-line to challenge exceptional players with 35 awesome civilizations for your quest for worldwide domination for the duration of the ages.

Pick out your direction to greatness with this definitive remaster to one of the maximum loved method games of all time.

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  • Os: home windows 10 64bit
  • Processor: intel center 2 duo or amd athlon 64×2 5600+
  • Memory: four gb ram
  • Portraits: nvidia® geforce® gt 420 or ati™ radeon™ hd 6850 or
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The Insurance Society of New York

The Insurance Society of New York
The Insurance Society of New York

The subject of insurance forms is such an exceedingly broad one, that it will be impossible in an address such as this to do more than touch upon it in a general way, and direct attention to some of the more important forms, which, although in general use, may possess features which are not fully understood.
The best form, whether viewed from the standpoint of the insurance company or the insured, is a fair form, one which expresses in clear, unambiguous language the mutual intention of the parties, and affords no cause for surprise on the part of either, after a loss has occurred. But the prepara¬ tion of such a form is not always an easy task, and it is right at this point that the ability of the broker and the underwriter come into play.
A distinguished Englishman declared that the English Constitution was the greatest production that had ever been conceived by the brain of man, but it was subjected to the most scathing criticism and violent assaults by Bentham, the great subversive critic of English law. Twenty-five years ago the New York Standard Policy was prepared by the best legal and lay talent in the insurance, world, and the greatest care was taken to present not only a reasonable and fair form of contract between the insurer and the insured, but one which could be easily read and understood.
While no such extravagant claims have been made for the Standard Policy as were made for the “Matchless Con-maximum of loss collection with a minimum of co-insurance or other resistance than a present day broker, he has not yet been discovered.
The ornate policies in use thirty years ago, with no uniformity in conditions, with their classification of hazards which no one could understand and their fine print which few could read, have given way to plainly printed uniform Standard Policies with materially simplified conditions. But the written portion of the insurance contract owing to our commercial and industrial growth, instead of becoming more simple, has taken exactly the opposite direction, and we now have covering under a single policy or set of policies, the entire property of a coal and mining company, the breweries, public service or traction lines of a whole city and the fixed property, rolling stock and common carrier liability of an entire railroad system involving millions of dollars and con¬ taining items numbering into the thousands. This forcibly illustrates the evolution of the policy form since the issue of the first fire insurance contract by an American company one hundred and sixty years ago, in favor of a gentleman bearing the familiar name of John Smith, covering
“500 £ on his dwelling house on the east side of King Street, between Mulberry and Sassafras, 30 feet front, 40 feet deep, brick, 9-inch party walls, three stories in height, plas¬ tered partitions, open newel bracket stairs, pent houses with board ceilings, garrets finished, three stories, painted brick kitchen, two stories in height, 15 feet 9 inches front, 19 feet 6 inches deep, dresser, shelves, wainscot closet fronts, shingling 1-5 worn.”
It will be observed that in the matter of verbiage this primitive form rivals some of our present day household furniture forms and all will agree that this particular dwelling might have been covered just as effectually and identified quite as easily without such an elaborate description.
Any one who has an insurable interest in property should be permitted to have any form of contract that he is willing to pay for, provided it is not contrary to law or against public policy, and judging from a contract of insurance issued by a certain office not long ago the insuring public apparently has no difficulty in securing any kind of a policy it may desire at any price it may be willing to pay. The contract in ques¬ tion was one for £20,000, covering stock against loss from any cause, except theft on the part of employes, anywhere in the Western Hemisphere, on land or water, without any con¬ ditions, restrictions or limitations whatsoever, written at less than one-half the Exchange rate in the insured’s place of business. An insurance agent upon being asked whether he thought it was good, said that if the company was anywhere near as good as the form, it was all that could be desired, but vouchsafed the opinion that it looked altogether too good to be good.

The Insurance Society of New York
The Insurance Society of New York

In these days we frequently find concentrated within the walls of a single structure one set of fire insurance policies covering on building, another on leasehold interest, another on rents or rental value—and in addition to this, policies for various tenants covering stock, fixtures, improvements, profits and use and occupancy, subject to the 100% average or co-insurance clause, to say nothing of steam boiler, casualty and liability insurance, thereby entirely eliminating the ele¬ ment of personal risk on the part of the owners, and produc¬ ing a situation which will account in some measure for the 17,000 annual fire alarms and $15,000,000 fire loss in New York City; $230,000,000 annual fire loss in the country at large, and for the constantly increasing percentage of cases where there are two or more fires in the same building and two or more claims from the same claimant.
The most common and perhaps least understood phrase found in policies of fire insurance is what is known as the “Commission Clause,” which reads “his own or held by him in trust or on commission or sold but not delivered” or “re¬ moved.” This clause in one form or another has been in use for many years, and it was originally the impression of un¬ derwriters that owing to the personal nature of the insurance contract a policy thus worded would simply cover the prop¬ erty of the insured and his interest in the property of others, such as advances and storage charges, but the courts have disabused their minds of any such narrow interpretation and have placed such a liberal construction upon the words “held in trust” that they may be justly regarded as among the broadest in the insurance language and scarcely less com¬ prehensive than the familiar term “for account of whom it may concern”; in fact, the principles controlling one phrase are similar to those governing the other.
It has been held that whether a merchant or bailee has assumed responsibility, or agreed to keep the property cov¬ ered or whether he is legally liable or not, if his policies contain the words “held in trust,” the owner may, after a fire, by merely ratifying the insurance of the bailee, appro¬ priate that for which he paid nothing whatever and may file proofs and bring suit in his own name against the bailee’s insurers. Nor is this all, for in some jurisdictions, if the bailee fails to include the loss on property of the bailor in his claim against his insurers, or if he does include it and the amount of insurance collectible is less than the total loss, the bailee may not first reimburse himself for the loss on his own goods and hold the balance in trust for the owners, but must prorate the amount actually collected with those own¬ ers who may have adopted the insurance, although, if he has a lien on any of the goods for charges or advances, this may be deducted from the proportion of insurance money due such owners The phrase “for account of whom it may concern” was formerly confined almost entirely to marine insurance, but in recent years there has been an increasing tendency to intro¬ duce it into policies of fire insurance.
All authorities are agreed that the interests protected by a policy containing these words must have been within the contemplation of him who took out the policy at the time it was issued. It is not necessary that he should have in¬ tended it for the benefit of some then known and particular individuals, but it would include such classes of persons as were intended to be included and who these were may be shown by parol. The owners or others intended to be cov¬ ered may ratify the insurance after a loss and take the bene¬ fit of it, though ignorant of its existence at the time of the issuance of the policy, just the same as under the term “held in trust.”
The words “for account of whom it may concern” are not limited in their protection to those persons who were concerned at the time the insurance was taken out, but will protect those having an insurable interest and who are con¬ cerned at the time when the loss occurs. They will cover the interest of a subsequent purchaser of a part or the whole of the property and supersede the alienation clause of the policy (U. S. S. C.), Hagan and Martin vs. Scottish Union and National Ins. Co., 32 Ins. Law Journal, p. 47; 186 U. S. 423).
A contract of insurance written in the name of “John Doe & Co. for account of whom it may concern” should contain a clause reading “Loss, if any, to be adjusted with and payable to John Doe & Co.,” not “loss, if any, payable to them” or “loss, if any, payable to the assured,” as forms sometimes read.
Policies are frequently written in the name of a bailee covering “On merchandise, his own and on the property of others for which he is responsible,” or “for which he may be liable”—and it has been held that’the effect of these words is to limit the liability of the insurer to the loss on the assured’s own goods and to his legal liability for loss on goods belonging to others, but the words “for which they are or may be liable” have been passed upon by the Supreme Court of Illinois, and they have been given an entirely dif¬ ferent interpretation. That tribunal in the case of The Home Insurance Company vs. Peoria & Pekin Union Railway Co. (28 Insurance Law Journal, p. 289; 178 Ills. 64) decided that the words quoted were merely descriptive of the cars to be insured; that the word “liable” as used in the policy did not signify a perfected or fixed legal liability, but rather a con¬ dition out of which a legal liability might arise.
As illustrative of its position the court said that an assignor of a negotiable note may, with no incorrectness of speech, be said to be liable upon his assignment obligation is not an absolute fixed legal liability but is con¬ tingent upon the financial condition of the maker; and ac¬ cordingly held that the insurance company was liable for loss on all the cars in the possession of the railroad company, notwithstanding the fact that the latter was not legally liable to the owners.
In view of the exceedingly broad construction which the courts have placed upon the time honored and familiar phrases to which reference has been made, it is important for the party insured, whether it be a railroad or other transportation company, a warehouseman, a laundryman, a tailor, a com¬ mission merchant or other bailee, to determine before the fire whether he desires the insurance to be so broad in its cover as to embrace not only his own property and interest, but also the property of everybody else which may happen to be in his custody; if so, he should be careful to insure for a sufficiently large amount to meet all possible co-insurance conditions,, and if he wishes to make sure of being fully reimbursed for his own loss, his only safe course is to insure for the full value of all the property in his possession.
At this point the inquiry which naturally presents itself is, how should a policy be written if a merchant, warehouse¬ man or other bailee desires to protect his own interest but not the interest of any one else? The following form is suggested: “On merchandise his own, and on his interest in and on his legal liability for property held by him in trust or on commission or on joint account with others, or sold but not removed, or on storage or for repairs, while con¬ tained, etc.” This will, it is believed, limit the operation of co-insurance conditions and at the same time prevent the owners from adopting, appropriating or helping themselves to the bailee’s insurance, for which they pay nothing and to which they are not equitably entitled.
Many of the household furniture forms now in use, in addition to embracing almost every conceivable kind of per¬ sonal property except that specifically prohibited by the pol¬ icy conditions, are also made to cover similar property be¬ longing to any member of the family or household, visitors, guests and servants.
This form would seem to indicate considerable ingenu¬ ity on the part of the broker, broad liberality on the part of the insurance company and commendable generosity on the part of the insured, and the latter would probably feel more than compensated by being able to reimburse his guest for any fire damage he might sustain while enjoying his hospi¬ tality, but the amount of insurance carried under such a form should anticipate the possibility of his having a number of guests at one time and a corresponding increase in the value at risk.
It must be borne in mind that in localities where co- insurance conditions prevail the value of property belonging