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7.
The defendant filed an answer to the complaint setting up in
several separate defenses that the respective causes of action of the
plaintiff are barred by the statute of limitations of the State of New Jersey,
and the plaintiff alleges that as to the counts of negligence set forth in the
complaint at law, the effect of the statute and its construction by the courts,
is to create a bar to the causes of action alleged by the plaintiff in the
action at law upon the counts aforesaid.
8,
The materials used in making said luminous paint and the im-
plements employed in mixing and applying said paint were furnished by the
defendant and the plaintiff was instructed in the manner in which said
materials were to be mixed and the said paint applied by the agents and
servants of the defendant.
9.
Prior to the employment by the defendant of the plaintiff and
during the period of such employment, the defendant had knowledge, actual and
imputed, that the materials furnished to the plaintiff in the performance of
her duties, as aforesaid, contained substancez which were dangerous, poisonous
and deleterious to the body and health of the plaintiff, and knew or should
have known that the mathod and manner in which the defendant instructed the
plaintiff to use and apply said materials and paint were so devised as to ex-
pose the plaintiff to the dangerous, poisonous and deleterious properties of
the ingredients of the said materials. The defendent knew the said facts, both
from actual experience in the use of the said substences and from scientific
experimentation carried on by it, and by others to its knowledge, and from
other scientific knowledge available and known to it.
10.
otwithstanding the fact that the relationship of master and
servant existed between the defendant and the plaintiff for the period stated
in the complaint above mentioned, and that the defendant was obliged to inform
the plaintiff of all unusual risks attending her employment which were not
obvious to or discoverable by the plaintiff, and the independent obligations of
defendant to plaintiff, the defendant fraudulently concealed from the plaintiff
facts known to it and of which it was charged with knowledge respecting the
dangerous and injurious nature of the substances above mentioned as hereinabove
stated, and concealed in the same manner that unusual risks attended the em-
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Context sent to Scholar
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"ocrText": "7.\nThe defendant filed an answer to the complaint setting up in\nseveral separate defenses that the respective causes of action of the\nplaintiff are barred by the statute of limitations of the State of New Jersey,\nand the plaintiff alleges that as to the counts of negligence set forth in the\ncomplaint at law, the effect of the statute and its construction by the courts,\nis to create a bar to the causes of action alleged by the plaintiff in the\naction at law upon the counts aforesaid.\n8,\nThe materials used in making said luminous paint and the im-\nplements employed in mixing and applying said paint were furnished by the\ndefendant and the plaintiff was instructed in the manner in which said\nmaterials were to be mixed and the said paint applied by the agents and\nservants of the defendant.\n9.\nPrior to the employment by the defendant of the plaintiff and\nduring the period of such employment, the defendant had knowledge, actual and\nimputed, that the materials furnished to the plaintiff in the performance of\nher duties, as aforesaid, contained substancez which were dangerous, poisonous\nand deleterious to the body and health of the plaintiff, and knew or should\nhave known that the mathod and manner in which the defendant instructed the\nplaintiff to use and apply said materials and paint were so devised as to ex-\npose the plaintiff to the dangerous, poisonous and deleterious properties of\nthe ingredients of the said materials. The defendent knew the said facts, both\nfrom actual experience in the use of the said substences and from scientific\nexperimentation carried on by it, and by others to its knowledge, and from\nother scientific knowledge available and known to it.\n10.\notwithstanding the fact that the relationship of master and\nservant existed between the defendant and the plaintiff for the period stated\nin the complaint above mentioned, and that the defendant was obliged to inform\nthe plaintiff of all unusual risks attending her employment which were not\nobvious to or discoverable by the plaintiff, and the independent obligations of\ndefendant to plaintiff, the defendant fraudulently concealed from the plaintiff\nfacts known to it and of which it was charged with knowledge respecting the\ndangerous and injurious nature of the substances above mentioned as hereinabove\nstated, and concealed in the same manner that unusual risks attended the em-"
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