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and of defendant's neglect to warn the said plaintiff of the dangerous nature of the said radioactive substances plaintiff, Albina Larice has become sick, sore lame and disabled and has suffered, still suffers and will continue to suffer great pain both mental and physical and has been prevented and will be prefented from pursuing and transacting her lawful business and plaintiff, Albina Larice has likewise been compelled and will be in the future compelled to outlay and expend great sums of money in an endeavor to 'be cured of said disability and incapacity received as aforesaid. Plaintiff, Albina Larice demands One Hundred and Twenty-five Thousand ($125,000) Dollars damages on the second count. THIRD COUNT. 1. The plaintiff, James A. Larice repeates the allegations of para- graphs 1 to 9 inclusive of the first count and paragraphs 1 to 7 inclusive of the second count as paragraph 1 of the third count. 2. The plaintiff, Albina Larice mentioned in the first and second counts of this complaint is the wife of the plaintiff James A. Larice. 3. By reason of the defendant's negligence as set out in the first and second counts of this complaint the said Albina Larice sustained the injuries as set out in the first and second counts and in consequence of said injuries the plaintiff, James A. Larice lost the services of his daid wife and in the future will be deprived of the services of his said wife and has in the past and will in the future be deprived of the comfort and aid of her society and has been and in the future will be compelled to lay out and expend large suns of money for doctor bills and medicines in an endeavor to treat and cure his said wife of her injuries. Plaintiff, James A. Larice demands Twenty-five Thousand ($25,000) Dollars damages on the third count. (signed) Potter. & Berry Attorneys of Plaintiffs

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5
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0
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853f33ab82a9318e
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Document data

ID
75721699
Core
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Type
document
DTO data
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Document identity
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Document source metadata
{
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        "Safety Light Collection",
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Document source extras
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Page context
{
    "seq": 5,
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    "type": "photo",
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    "ocrText": "and of defendant's neglect to warn the said plaintiff of the dangerous\nnature of the said radioactive substances plaintiff, Albina Larice has\nbecome sick, sore lame and disabled and has suffered, still suffers and\nwill continue to suffer great pain both mental and physical and has been\nprevented and will be prefented from pursuing and transacting her lawful\nbusiness and plaintiff, Albina Larice has likewise been compelled and\nwill be in the future compelled to outlay and expend great sums of money\nin an endeavor to 'be cured of said disability and incapacity received as\naforesaid.\nPlaintiff, Albina Larice demands One Hundred and Twenty-five Thousand\n($125,000) Dollars damages on the second count.\nTHIRD COUNT.\n1. The plaintiff, James A. Larice repeates the allegations of para-\ngraphs 1 to 9 inclusive of the first count and paragraphs 1 to 7 inclusive\nof the second count as paragraph 1 of the third count.\n2. The plaintiff, Albina Larice mentioned in the first and second\ncounts of this complaint is the wife of the plaintiff James A. Larice.\n3. By reason of the defendant's negligence as set out in the first\nand second counts of this complaint the said Albina Larice sustained the\ninjuries as set out in the first and second counts and in consequence of\nsaid injuries the plaintiff, James A. Larice lost the services of his daid\nwife and in the future will be deprived of the services of his said wife\nand has in the past and will in the future be deprived of the comfort and\naid of her society and has been and in the future will be compelled to lay\nout and expend large suns of money for doctor bills and medicines in an\nendeavor to treat and cure his said wife of her injuries.\nPlaintiff, James A. Larice demands Twenty-five Thousand ($25,000)\nDollars damages on the third count.\n(signed)\nPotter. & Berry\nAttorneys of Plaintiffs"
}