SOGNIER, Chief Judge.
Steven Jackson was involved in a collision with Mary Johns while driving a car he rented from Atlanta Rent-A-Car, Inc. ("ARAC"). Johns's automobile insurance carrier paid her claim and then filed a subrogation action against Jackson. In turn, Jackson brought a third-party complaint for indemnification against ARAC, a self-insurer, and ARAC counterclaimed on the basis of an indemnification clause in the
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