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oring to be cured of said disability and incapacity received as afore-
said and plaintiff has likewise suffered great loss in that she, be-
cause of her disability and incapacity received as aforesaid will be
unable to pursue a gainful occupation.
Plaintiff demands One Hundred Twenty-Five Thousand ($125000)
Dollars damages in the first count.
SECOND COUNT.
1. Paragraphs 1 and 2 of the first count are hereby repeated as
paragraph 1 of the second count.
2. During the period referred to in paragraph one of this count
plaintiff was employed as a servant of the defendant corporation to
work in defendant's factory in Orange aforesaid.
3. Defendant failed to provide the plaintiff with a safe place to
work but ordered and instructed the plaintiff to handle and to be
constantly in close proximity with quantities of dangerous radioactive
substances.
4. Plaintiff did not know of the dan gerous nature of the said radio-
active substances or their harmful effects upon the human body.
5. Defendant gave no warning to the plaintiff of the dangerous
nature of said radioactive substances into close proximity with which
plaintiff was brought but constantly ordered and directed plaintiff to
be brought into close proximity with said dangerous radioactive sub-
stances with the result that plaintiff was exposed to the penetrative
rays of the said radioactive substances and the emanations thereof and
plaintiff further injested said radioactive substances to the plain-
tiff's great damage.
6. Plaintiff reppats paragraphs 6,7, and 8 of the first count as
paragraph 6 of the second count.
7. As a result of the said introduction of the said dangerous
redioactive substances into the plaintiff's body and defendant's neg-
lect to provide a safe place for plaintiff to work and of defendant's
neglest to warn plaintiff of the dangerous nature of the said radio-
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"ocrText": "oring to be cured of said disability and incapacity received as afore-\nsaid and plaintiff has likewise suffered great loss in that she, be-\ncause of her disability and incapacity received as aforesaid will be\nunable to pursue a gainful occupation.\nPlaintiff demands One Hundred Twenty-Five Thousand ($125000)\nDollars damages in the first count.\nSECOND COUNT.\n1. Paragraphs 1 and 2 of the first count are hereby repeated as\nparagraph 1 of the second count.\n2. During the period referred to in paragraph one of this count\nplaintiff was employed as a servant of the defendant corporation to\nwork in defendant's factory in Orange aforesaid.\n3. Defendant failed to provide the plaintiff with a safe place to\nwork but ordered and instructed the plaintiff to handle and to be\nconstantly in close proximity with quantities of dangerous radioactive\nsubstances.\n4. Plaintiff did not know of the dan gerous nature of the said radio-\nactive substances or their harmful effects upon the human body.\n5. Defendant gave no warning to the plaintiff of the dangerous\nnature of said radioactive substances into close proximity with which\nplaintiff was brought but constantly ordered and directed plaintiff to\nbe brought into close proximity with said dangerous radioactive sub-\nstances with the result that plaintiff was exposed to the penetrative\nrays of the said radioactive substances and the emanations thereof and\nplaintiff further injested said radioactive substances to the plain-\ntiff's great damage.\n6. Plaintiff reppats paragraphs 6,7, and 8 of the first count as\nparagraph 6 of the second count.\n7. As a result of the said introduction of the said dangerous\nredioactive substances into the plaintiff's body and defendant's neg-\nlect to provide a safe place for plaintiff to work and of defendant's\nneglest to warn plaintiff of the dangerous nature of the said radio-"
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