Fallout 4 v1.10.163 Download

Fallout 4 v1.10.163 Fitgirl Repack Free Download PC Game

Fallout 4 v1.10.163 Fitgirl Repack Free Download PC Game final version or you can say the latest update is released for PC.And the best this about this DLC is that it’s free to download.In this Tutorial we will show you how to download and Install Fallout 4 v1.10.1643 Torrent for free.Before you download and install this awesome game on your computer note that this game is highly compressed and is the repack version of this game.

Download Fallout 4 v1.10.163 Fit girl repack is a free to play game.Yes you can get this game for free.Now there are different website from which you can download Fallout 4 v1.10.163 igg games and ocean of games are the two most popular websites.Also ova games and the skidrow reloaded also provide you to download this awesome game.

Fallout 4 v1.10.163 for Android and iOS?

Yes you can download Fallout 4 v1.10.163 on your Android and iOS platform and again they are also free to download.

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How To download and Install Fallout 4 v1.10.163

Now to download and Install Fallout 4 v1.10.163 for free on your PC you have to follow below given steps.If there is a problem then you can comment down below in the comment section we will love to help you on this.

  1. First you have to download Fallout 4 v1.10.163 on your PC.You can find the download button at the top of the post.
  2. Now the download page will open.There you have to login .Once you login the download process will starts automatically.
  3. If you are unable to download this game then make sure you have deactivated your Ad blocker.Other wise you will not be able to download this game on to your PC.
  4. Now if you want to watch game Installation video and Trouble shooting tutorial then head over to the next section.

TROUBLESHOOTING Fallout 4 v1.10.163 Download

Screenshots  (Tap To Enlarge)

 Now if you are interested in the screen shots then tap down on the picture to enlarge them.

Fallout 4 v1.10.163 Review ,Walkthrough and Gameplay

Number one question I get in all of my Fallout 4 v1.10.163 fitgirl repack in my streams is what mods do you use so today I wanted to go over the top 15 essential mods for horizon that I simply just cannot live without there are many many more mods that I use .That I have recommended in my full mod spreadsheet.But these 15 are the ones I would recommend the most.Of course I’ll have every mod listed in the description down below so you can go .Download them yourself in this first section I want to go over Fallout 4 v1.10.163 igg games enhancements so this is really the core of this video .If you get nothing else these are the mods.

I would recommend you get first off we have keep Commonwealth radiant quests within the Commonwealth by real assassin so if you’re like me you’ve probably discovered that the best what it or an experience in horizon is by finding your factions.Doing their repeatable radiant quests the problem is the first time you go.Talk to scribe Halon she’s gonna send you to far harbor or Fallout 4 v1.10.163 update download world or somewhere else that you can’t get to whenever you’re level 10 or whatever you are whenever you actually first meet them this mod fixes that by forcing all commonwealth radiant quests to stay within the Commonwealth next up we have def Fallout 4 v1.10.163 download.Succumbs again I hope I’m pronouncing all of your names correctly death UI is a major enhancement to the vanilla hue .

I that makes it much more friendly towards PC especially whenever you are looting things or transferring things in your workshop def UI is entirely compatible with Horizon however you’ll want to install def UI first .Then install horizon afterwards overwriting your def Fallout 4 v1.10.163 download install next up we have auto loop by a fire under this simply allows you to automatically loot containers that are on the ground where anywhere else within the vicinity that you set this will be a controversial one some people will say this is cheating.Technically yes it is it’s a cheat I mean it simply dilutes things for you however if you’ve ever seen me play horizon or if you ever played it yourself you’ll know that looting in horizon is tedious you have to pick up literally everything so rather than walking into a room .Spamming e for several minutes this mods to be loose those things for me initially .

I got this mod to enhance my viewers experience whenever I’m streaming because let’s face it nobody wants to watch somebody loot stuff for 20 or 30 minutes straight however after using it for some time I have to admit that even if I was not streaming I would still probably use this now you can set it to actually automatically open locks for you however in terms of balance I would say that is not the way to go also be aware of that Auto loot has been reported to crash some people however I found that by turning body looting off .Setting most of your stuff to go to settlements I don’t have very many problems with it in my opinion all this module 8 does is expedite the looting process.Lets me get to the portion of the game .I like better which is combat, building settlements next up in Fallout 4 v1.10.163 fitgirl repack we have better settlers by Tom 293 this does a couple of things it makes your settlers a bit more varied.The main reason I use it is because whenever I hit that Bell to get my settlers to gather round they don’t dilly-dally they run quickly that really gets annoying whenever.

I go to a settlement.I want to go ahead and harvest all of my crops.My settlers are just kind of milling around not doing anything waiting forever to come over to the Bell whenever I ring it optionally you can also add the community clothing an armored pack which adds even more variety in settler outfits as well as more variation in the settlers themselves next up we have scrapped everything by shadow slasher 4/10 and Vitz this simply allows you to scrap far more objects than you normally could in the game there is a patch for this and horizon.Make sure that you use it otherwise you’ll beginning far more materials than you really should be now the horizon mod offer has made that it it’s not quite perfect yet there are some things he would like to probably add to the scrap list.There are some things that maybe should not be on there.For now it’s a good alternative if you don’t want to use something like spring cleaning or the regular version scrapped everything which kind of unbalances the game when you’re playing horizon.

Next up is place everywhere by the Lich place everywhere simply allows you to place anything anyway in the fallout 4 building menu it also allows you to do things like snapping the alignment of objects to the workshop grid so that you can line things up no longer will you have to manually tweak how your beds are lined up they will be nice and straight and flush against the.You can also turn object snapping on or off as well as a lot of other features next up we have fall complete by Kefka 95 quite simply this adds .

Ability to mark on your map the locations of magazines bobble heads etc personally I use this to track down magazines and bobble heads because magazines serve a very important function in horizon as an example in order to craft most ammunition you have to find issues of the guns and bullets magazine so no longer all these magazines just a nice-to-have thing they are required for you to progress in horizon in a reasonable manner .Again this could be considered a cheat,because in horizon these are really required to progress your character .

I feel like this is a must-have mod finally wrapping up the gameplay section we have quicktrade by registrate or 2000 quicktrade simply allows you to walk up to any vendor press the hour button or whatever key you have it bound to enter into the trade menu with them no longer do you have to here myrna tell you for the 10000 time everything to everyone except sense no sense allowed here now you can just walk up to her press the r button get your trade done get out of there next up we have the visual section now I don’t have a ton of visual stuff here visual stuff is mostly personal taste .It’s going to depend on how powerful your computer is.But there are three that I’m going to recommend first off we have optimized on the textures by mist this simply makes availa textures much more optimized they’ll run better.

They’ll also look better on most computers next up we have enhanced blood textures by de finder this quite simply overhauls blood splatters blood spurts anything to do with blood in the game .Makes it look far more realistic ,let’s be honest a bit more glory because default fallout 4 it just isn’t all that gory it’s not really that scary or disgusting looking finally.

I’m going to recommend the entire vivid Fallout 4 v1.10.163 download that would be vivid fallout roads and bridges trees and landscapes all of them by hi in 84 this is a great series that both will improve your performance .Make the game look better what is it with Bethesda.Having textures that are unoptimized that still look like crap well that should wrap up the visual section now we’ll move on to sound I only have one sound mod here .That sound mod is thought-out suite by Fallout suite this soundtrack extension is amazing it adds brand-new original soundtracks to the exploration suite of Fallout 4 they depend on weather.Time of day .They fit perfectly with the atmosphere if you hadn’t told me that these were new original tracks I would not have known .

Some of them are honestly almost better than the original exploration suite .Finally I want to go over some mods that add either a new gear or a variety in the existing gear the first one is armorsmith extended by gambit 77 this mod adds the ability to wear whatever you want with whatever you want so if you want to wear a dapper looking tan suit with a set of combat armor or if you’d like to wear farmer’s clothing with leather armor whatever you want you can do it next up we have Ellie’s armor compendium by Eleonora this is a mod that I saw featured by MX are quite some time ago.

It continues to be one of the best armor mods in the game quite simply this adds many new outfits that you can wear and they all look absolutely stunning my personal favorites are the faction jumpsuits .The road Fury outfit .But there are many many more choose from finally for the gear section we have the official horizon weapon merch pack by said Zilla.Of course the horizon mod offer himself Izawa Newell.I hope I am pronouncing that correctly I normally just call him mr. Z this adds new weapons that are entirely lower friendly that come from previous games in the Fallout series you’ll find old fan favorites like the China Lake the crude blowback the varmint rifle the watch mm laser carbine.

If you’ve been involved in an accident involving an 18-wheeler, Munley Law can assist in making things right

If you or your loved ones were wounded or even killed as a result of an accident that involved an 18-wheeler and you are in need of help, we’d like to provide you with an initial consultation for free with one of the country’s most renowned truck accident attorneys. The law office we represent is committed in helping the victims from all kinds in truck-related accidents which includes commercial vehicles with 18 wheels. We’ve fought for years against trucking companies , and have won cases on behalf of victims of truck accidents, exactly like you. We have the knowledge and resources to tackle these corporations and we’d like to help you.

$32 MillionWrongful Death

$26 MillionTruck Accident

$17.5 MillionCar Accident

$12 MillionProduct Liability

$8 MillionTruck Accident

$8 MillionTruck Accident/Wrongful Death

$7.5 MillionAuto Accident

$6.9 MillionGarbage Truck Crash

$6.5 MillionTraumatic Brain Injury

$5 MillionMedical Malpractice

$5 MillionBus Accident

$4.7 MillionTruck Accidents

Injuries resulting from 18-wheeled trucks affect over 90,000 people each year. And every 16 minutes, a person is injured or killed in a collision with a truck. Since the past 10 years fatal truck crashes have been increasing as the trucking industry continues to ask for a relaxation of safety rules.

If you or your loved one was wounded or even killed as a result of an incident caused by an 18-wheeler vehicle, call Munley Law today to schedule a no-cost case review. There is no cost for the consultation and we won’t be paid until we prevail in your case.

We are the best 18-wheeler accident lawyers in the nation.

A lot of legal firms claim to deal with truck accident cases however, few firms can boast the know-how and experience needed to effectively represent an accident victim. Accidents involving commercial vehicles and huge 18-wheelers must be handled by only be handled by an attorney with a an established track record of success on large transportation companies and an in-depth understanding of the laws, regulations, technology insurance and other practices.

This kind of experience and an impressive track record The combination of this expertise and a proven track record makes Munley Law one of the best lawyers for truck crashes. Our lawyers have gained national recognition as the profession’s top lawyer for truck accidents. Our law office is the sole one within the United States with two lawyers who have served as the chair of the American Association for Justice Trucking Litigation Group. Marion Munley and Daniel Munley are among a few lawyers to have received the board certification for Truck Accident Law from the National Board of Trial Advocacy. Our 18-wheeler and tractor trailer lawyers achieve amazing outcomes as that’s what our clients are entitled to.

If you’ve been involved in an accident with an 18-wheeler it’s a high-risk situation. There’s a chance that you’ll be faced with injuries, medical bills and a bleak future. You’ve not had to face any major lawsuits in the past, but trucking firms have – they have teams of employees charged with delaying the claim or even denying it entirely. We will not let this occur. Let’s start from here.

Common Causes of 18-Wheeler Accidents

One of the primary goals for your lawyer who handles truck accidents is to determine which circumstances and actions contributed to the accident. The 18-wheelers crash due to various motives, such as:

  • Overloaded or Improperly Loaded Vehicles
  • Fatigued Driving
  • Impaired Driving Under the Influence of Drugs or Alcohol
  • Distracted Driving
  • Speeding, Especially Around Sharp Curves
  • Inclement Weather Such as Snow, Rain, Hail, Fog, Wind, Sleet, or Ice
  • Failure to Perform Required Inspections and Maintenance
  • Manufacturing Defects
  • Tire Blowouts
  • Worn Brakes
  • Installation Defects

To pinpoint the cause (and to hold the responsible individuals accountable for the damages you sustained) we’ll collaborate with the top experts and conduct a thorough investigation.

Reasons 18-Wheelers Are So Dangerous

  • They carry heavy loads When carrying an entire load, an 18-wheeler weighs an average of 80,000 pounds. This is about 400 tons. To put that figure into perspective an average car weighs approximately 2700 pounds. That’s one ton. That’s a lot of 18-wheelers. four times more heavy than the majority of the vehicles they share the roads with. When 18-wheelers meet with other motor vehicles their weight result in severe injuries, massive destruction to property, as well as, unfortunately tragic deaths.
  • They are the largest vehicles that you can see on the Road 18-wheelers can exceed the length of 176 feet and could have as many as four trailers! That means that the 18-wheeler sitting right next in front of you along the road is more than the length of the size of a football field, and more than 10 times the length of the average vehicle. The huge length of the truck can make it difficult for drivers to avoid crashes as they negotiate sharp curves on the road, turning, merging, expressway exits and narrow roads. Their huge size increases the risk of roadside negligence such as speeding. A 18-wheeler truck that travels at 70 miles an hour will consume twice as much energy as a vehicle traveling at 50 miles an hour.
  • They require more time and space to stop The amount of time it takes for an 18-wheeler to slow down and come to a stop completely is around 40% more than what cars need. A lot of motor vehicle drivers who are behind 18-wheelers don’t know how much space they must leave between their vehicle and the huge truck ahead of them.
  • They have huge blind spots Contrary to sedan, hatchback minivan, SUV, as well as pickups, the 18-wheelers do not have the rear window. 18-wheeler truckers therefore have to depend on rear-view mirrors to see what’s behind them. However, due to the size of the trailer and truck’s dimensions, they have huge blind spots.

Why You Should Hire a Top Truck Crash Lawyer

In the event that you, or someone you know was involved in an accident involving an 18-wheeled vehicle and you know you were not at fault and believe that the injuries and the expenses resulted from the accident are evident, and you’re wondering why you’d require a lawyer to represent you.

trucking Companies regularly deny responsibility and aggressively defend nearly every caseSince there are hundreds of trucking accidents each year and trucking companies are experienced in the most effective strategies to avoid responsibility and the expenses associated with accidents caused by their 18-wheeler drivers. A majority of trucking firms will send their representatives to their way to the site of an incident in a matter of hours or minutes , and they begin to gather evidence to settle any claim you might file against them.

Our truck accident lawyers have years of experience and are regarded as the most trusted law firm for truck accident cases across the country. Our lawyers have won many agreements and settlements in the case of 18 wheeler transport companies . If you work with an attorney from our team of trucking lawyers The trucking companies are aware that they will be up against the most experienced and best truck crash companies across the country.

18-Wheeler Collision with a Truck Cases are Complex because 18-wheelers, car accidents and medical injuries can be complicated by their nature, litigation involving truck accidents is also. These cases involve complex concepts that span chemistry, physics as well as federal trucking regulations, medical, biology driving standards, economics. When a case that is that is based on an 18-wheeler accident is brought to trial, the victims of accidents will need to present their case to the jury by describing what transpired using all of the complicated science and industry-specific theories and concepts.

We are Truck Accident Team at Munley Law has spent over 60 years learning about the specifics in the industry of trucking, as well as the science of truck accidents, as well as the most effective strategies for negotiation and trial to secure a huge settlement on behalf of our customers. We have created an expert team who knows how to make use of experts in the field and witnesses, graphic representation, and technology to demonstrate why the victims you are entitled to compensation.

  • The award you are entitled to requires a lot of resources The trucking and insurance firms have plenty of cash and staff to draw upon and use it to force victims of accidents to leave or accept settlements significantly less than they should. To be able to be able to fight for the money you’re entitled to after being the victim of an accident involving an 18-wheel and to win, you must match the insurance and trucking firms’ vast resources, so you can engage experts to consult and testify in court to utilize the latest technology to show your case before a jury.

This is where our truck crash attorneys at Munley Law can help. We don’t just have the years of experience in litigation for 18-wheelers you require, but we they also have the cash and legal team to go to court in order to argue your case and win. We cover all expenses in your truck crash lawsuit in advance and you’ll pay us nothing if you don’t get you a huge settlement.

Frequently Asked Questions in 18-Wheeler Truck Crash Cases

Q What can I do to safeguard myself from a truck 18-wheeler accident?

A: The initial and foremost thing to do is to get a successful and experienced attorney for accidents involving 18-wheelers. Combating large trucking companies is something that you’ll need expertise to master. They have a wealth of resources, with lawyers and experts who are more than capable of fighting any lawsuits that come their way. If you’ve been injured in a crash involving an 18-wheeler get in touch with a skilled truck accident lawyer from Munley Law who will ensure that you get the amount you deserve.

Q How should I proceed right away after an 18-wheeler accident?

A: If you’re ever involved in a collision with an 18-wheeler here are the steps to do at the scene:

  • Keep calm and inside the vehicle (unless you have to leave for reasons of safety)
  • Contact 911 (even when you think your accident is not serious)
  • Get medical attention at the scene of any accident who suffers injuries of any nature
  • Do not move your vehicle till the time that police are on site (unless absolutely needed)
  • Don’t quit the scene
  • Note down all names, addresses, and telephone numbers of all participants, including witnesses
  • Note down the badge numbers and names of any officers who are investigating the accident.
  • Take pictures of the area, which includes the vehicles as well as the injuries
  • Do not be ashamed to admit your the fault
  • Contact your insurance company.
  • Do not discuss the incident with anyone other than you and the police, or with your personal insurance agent or representative. you do not have to provide a statement to anyone else than you and the insurance provider.

Q How should I proceed after an 18-wheeler semi-truck crash?

A: Here’s what you should do following an 18-wheeler semi-truck accident:

  • Take a copy of the incident investigation report by the police. Also, get the valuation of property damage from the insurance company.
  • Keep a log of your visits to doctors and other healthcare professionals. Record all symptoms or pains that you feel. Keep copies of the results of any tests and treatments, medications and any other medical treatment.
  • Make a list of all costs out-of-pocket that you pay for injuries or as a result of your crash.
  • Keep a log of the time you the absences from work or other activities that injuries prevented you from engaging in.
  • Speak with a lawyer prior to signing any settlement agreements.

Q Who can you to sue in an 18-wheeler crash?

A: Accidents involving trucks are more complex due to the larger number of those who may be responsible. This could include: the driver of the truck, firm that handles the truck as well as who owns the trailer or truck as well as the third party manufacturer as well as the company that is responsible to load the truck and even the organization accountable on the content of the trailer. The best way to decide the best course of action for your specific semi-truck accident is to consult an attorney.

Q: What is the time frame I must follow for a court case following an accident with a truck?

A: In the majority of states including Pennsylvania the time limit for filing a crash involving an 18-wheeler incident is two years following the incident. Don’t wait for two years before filing. The case is simpler to analyze and recover compensation when you are closer you get to the date of the incident, so that the information and evidence are fresh. If you delay, crucial evidence could disappear or be destroyed. This gives the trucking firm along with its personal team of experts and investigators on site of accident more time to prepare their defense.

Q: What is it going to cost to employ an attorney for an 18-wheeler truck crash?

A: We operate on a contingency-fee basis. What does that mean? We will not charge fees unless we prevail in your case. We do not charge you in advance or out of your personal pockets. We are Munley Law, we will not be paid until we receive your payment.

Q: Why Should I Choose Munley Law to Represent Me in My Truck Accident Case?

A An example: At Munley Law We have a proven track record of obtaining justice for those injured in truck accidents. This includes collisions that involve 18-wheeler truck. We have been so ardent and repeatedly for our clients that our lawyers have been recognized repeatedly as the best in the field of truck accident.

Munley Law has more experience in cases involving truck accidents that any law company located in Pennsylvania, New York, or New Jersey. Our wins in truck litigation include:

$32 MillionWrongful Death

$26 MillionTruck Accident

$17.5 MillionCar Accident

$12 MillionProduct Liability

$8 MillionTruck Accident

$8 MillionTruck Accident/Wrongful Death

$7.5 MillionAuto Accident

$6.9 MillionGarbage Truck Crash

$6.5 MillionTraumatic Brain Injury

$5 MillionMedical Malpractice

$5 MillionBus Accident

$4.7 MillionTruck Accidents

18 Wheeler Cases are Complex and Require Experience to get You the Justice You Deserve — So Choose Carefully

We have handled 18 wheeler cases for years our knowledge and experience is unrivaled. We have the experience to give you the best recuperation.

Munley Law is a family-run law firm. We take on your truck crash case with the full power that our team and we work together to get the most favorable outcome. We will also represent you in negotiations as well as in court We will also be there as your advocate to help you through this stressful time.

Chat live, call us or fill out our contact form and begin the process today.

Find out what our customers have to say on our behalf:

“I’m extremely grateful for my lawyers, who have never let me down and were willing to fight for me and my kids. It’s been a wonderful experience working with them , and I am so grateful for them. Since the amount of money they spent will change the fact that what happened to us, they made sure that we were always taken care of.” — Katy S., A Client of a Truck Accident

The Co-insurance Clause

The Co-insurance Clause
The Co-insurance Clause

Of the more important clauses in current use, the one most frequently used, most severely criticized, most mis¬ understood, most legislated against, and withal the most reasonable and most equitable, is that which in general terms is known as the “co-insurance clause.”
Insurance is one of the great necessities of our business, social and economic life, and the expense of maintaining it should be distributed among the property owners of the country as equitably as it is humanly possible so to do.
Losses and expenses are paid out of premiums col¬ lected. When a loss is total the penalty for underinsurance falls where it properly belongs, on the insured who has elected to save premium and assume a portion of the risk himself, and the same penalty for underinsurance should by contract be made to apply in case of partial loss as applies automatically in case of total loss.
If all losses were total, liberality on the part of the insured in the payment of premium would bring its own reward, and parsimony would bring its own penalty; but the records of the leading companies show that of all the losses sustained, about 65%—numerically—are less than $100; about 30% are between $100 and total; and about 5% are total. The natural inclination, therefore, on the part of the public, particularly on the less hazardous risks, is to under¬ insure and take the chance of not having a total loss; and this will generally be done except under special conditions, or when reasonably full insurance must be carried to sustain credit or as collateral security for loans. There were several strik¬ ing illustrations of this in the San Francisco conflagration, where the amount of insurance carried on so-called fireproof buildings was less than 10% of their value, and the insured in such instances, of course, paid a heavy penalty for their neglect to carry adequate insurance.
Co-insurance operates only in case of partial loss, where both the insurance carried and the loss sustained are less than the prescribed percentage named in the clause, and has the effect of preventing one who has insured for a small percentage of value and paid a correspondingly small pre¬ mium from collecting as much in the event of loss as one who has insured for a large percentage of value and paid a correspondingly large premium. We have high authority for the principle,
“He which soweth sparingly shall reap also sparingly, and he which soweth bountifully shall reap also bountifully.”
and it should be applied to contracts of insurance. Rating systems may come, and rating systems may go; but, unless the principle of co-insurance be recognized and universally applied, there can be no equitable division of the insurance burden, and the existing inequalities will go on forever. The principle is so well established in some countries that the general foreign form of policy issued by the London offices for use therein contains the full co-insurance clause in the printed conditions.
The necessity for co-insurance as an equalizer of rates was quite forcibly illustrated by a prominent underwriter in an ad¬ dress delivered several years ago, in the following example involving two buildings of superior construction:
“A’S” BUILDING “B’S” BUILDING
Value $100,000 Value $100,000
Insurance 80,000 Insurance 10,000
Rate 1% Rate 1%
Premium received— Premium received—
one year, 800 one year, 100
No Co-insurance Clause No Co-insurance Clause
Loss 800 Loss 800
Loss Collectible 800 Loss Collectible 800
“B” pays only one-eighth as much premium as “A,” yet both collect the same amount of loss, and in the absence of co-insurance conditions both would collect the same amount in all instances where the loss is $10,000 or less. Of course, if the loss should exceed $10,000, “A” would reap his reward, and “B” would pay his penalty. This situation clearly calls either for a difference in rate in favor of “A” or for a difference in loss collection as against “B,” and the latter can be regulated only through the medium of a co-insurance condition in the policy.
At this point it may not be amiss incidentally to inquire why the owner of a building which is heavily encumbered, whose policies are payable to a mortgagee (particularly a junior encumbrancer) under a mortgagee clause, and where subrogation may be of little or no value, should have the benefit of the same rate as the owner of another building of similar construction with similar occupancy, but unencum¬ bered.
In some states rates are made with and without co- insurance conditions, quite a material reduction in the basis rate being allowed for the insertion of the 80% clause in the policy, and a further reduction for the use of the 90% and 100% clauses. This, however, does not go far enough, and any variation in rate should be graded according to the co-insurance percentage named in the clause, and this gradation should not be restricted, as it is, to 80%, 90% or 100%, if the principle of equalization is to be maintained.
Various clauses designed to give practical effect to the co-insurance principle have been in use in this country for nearly forty years in connection with fire and other contracts of insurance. Some of these are well adapted to the purpose intended, while others fail to accomplish said purpose under certain conditions; but, fortunately, incidents of this nature are not of frequent occurrence.
There are, generally speaking, four forms, which differ quite materially in phraseology, and sometimes differ in prac¬ tical application. These four clauses are: (1) the old co- insurance clause; (2) the percentage co-insurance clause; (3) the average clause; (4) the reduced rate contribution clause.
Until recently, underwriters were complacently using some of these titles indiscriminately in certain portions of the country, under the assumption that the clauses, although differently phrased, were in effect the same, but they were subjected to quite a rude awakening by a decision which was handed down about a year ago by the Tennessee Court of Civic Appeals. The law in Tennessee permits the use of the three-fourths value clause and the co-insurance clause, but permits no other restrictive provisions. The form in use bore the inscription “Co-insurance Clause,” but the context was the phraseology of the reduced rate contribution clause, and although the result was the same under the operation of either, the court held that the form used was not the co- insurance clause, hence it was void and consequently inop¬ erative. Thompson vs. Concordia Fire Ins. Co. (Tenn. 1919) 215 S.W. Rep. 932, 55 Ins. Law Journal 122.
The law of Georgia provides that all insurance companies shall pay the full amount of loss sustained up to the amount of insurance expressed in the policy, and that all stipulations in such policies to the contrary shall be null and void. The law further provides that when the insured has several policies on the same property, his recovery from any company will be pro rata as to the amount thereof.
About twenty years ago, the Supreipe Court of Georgia was called upon to decide whether under the law referred to the old co-insurance clause then in use, which provided
“that the assured shall at all times maintain a total insurance upon the property insured by this policy of not less than 75% of the actual cash value thereof . . . . and that failing to do so, the assured shall
become a co-insurer to the extent of the deficiency,”
was valid and enforceable, and it decided that the clause was not violative of the law. Pekor vs. Fireman’s Fund Ins. Co. (1898) (106 Ga. page 1)

The Co-insurance Clause
The Co-insurance Clause
The court evidently construed the clause as a binding agreement on the part of the insured to secure insurance up to a certain percentage of value, and virtually held that if the insured himself desired to take the place of another insurance company he was at liberty to do so as one way of fulfilling his agreement.

The Georgia courts, however, have not passed upon the validity of the reduced rate contribution clause in connection with the statutory law above referred to; but it is fair to assume that they will view the matter in the same light as the Tennessee court (supra), and hold that it is not a co-insurance clause, even though it generally produces the same result; that it contains no provision whatever requiring the insured to carry or procure a stated amount of insurance, and in event of failure, to become a co-insurer, but that it is simply a clause placing a limitation upon the insurer’s liability, which is expressly prohibited by statute. The fact that the insurers have labeled it “75% Co-insurance Clause” does not make it such.
It is, therefore, not at all surprising that the question is frequently asked as to the difference between the various forms of so-called co-insurance clauses, and these will be considered in the order in which, chronologically, they came into use.
Probably in ninety-nine cases out of one hundred there is no difference* between these clauses in the results obtained by their application, but cases occasionally arise where ac¬ cording to the generally accepted interpretation the difference will be quite pronounced. This difference, which will be hereinafter considered, appears in connecton with the old co-insurance clause and the percentage co-insurance clause, and only in cases where the policies are nonconcurrent.
The first of the four forms is the old co-insurance clause which for many years was the only one used in the West, and which is used there still, to some extent, and now quite generally in the South. Its reintroduction in the South was probably due to the Tennessee decision, to which reference has been made (supra). This clause provides that the insured shall maintain insurance on the property described in the policy to the extent of at least a stated percentage (usually 80%) of the actual cash value thereof, and failing so to do, shall to the extent of such deficit bear his, her or their pro¬ portion of any loss. It does not say that he shall maintain insurance on all of the property, and the prevailing opinion is that the co-insurance clause will be complied with if he carries the stipulated percentage of insurance either on all or on any part of the property described, notwithstanding the fact that a portion of said insurance may be of no assist¬ ance whatever to the blanket, or more general policy, as a contributing factor.

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