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causing the plaintiff thereby great pain and suffering both montal and
physical.
9. The effect of the introduction of the said radioactive sub-
stances into the human body is such that the effect does not become
immediatoly apparent and plaintiff did not feel said effect or know of
the beginning of the continuing injury done her until several years
following her last exposure to said dangerous radioactive substances
and the plaintiff was not apprised of the nature of her bodfly ailments
or informed or Imew that her suffering was due to the negligence of
the defendants until July, 1925.
10. By reason of the premises plaintiff became, was and is sick, sora,
lame, disabled and crippled with continually increasing pain dnd suffer-
ing both mental and physical from the time of the consencement of her
illness unto the present, during all which time the plaintiff underwent
and suffered and will in the future undergo and suffer groat pain both
mental and physical and plaintiff has been, is and will be hindored and
prevented from transacting her lawful affairs and has been is and will
be deprived of divers large mins and money spent in endeavoring to be
cured of said disability and incapacity received as aforesaid and plain-
tiff has likewise suffered great loss in that she because of her disabil-
ity and incapacity received as aforesaid, has been unable and will be un-
able to pursue a gainful occupation.
Plaintiff demands against the defendant, United States Radium
Corporation, individually, and atainst The Luminite Corporation, indiv-
idually, and or agninst the United States Radium Corporation and The
Luminite Corporation jointly end or against the United States Radium
Corporation or in the alternative against the defendant The Luminite
Corporation, One Hundred and Twenty-five Thousand ($125,000) Dollars
damages on the first count.
SECOND COUNT
1. Paragraphs 1.2 and 3 of the first count are hereby repeated
as paragraph 1 of the second count.
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Context sent to Scholar
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"ocrText": "causing the plaintiff thereby great pain and suffering both montal and\nphysical.\n9. The effect of the introduction of the said radioactive sub-\nstances into the human body is such that the effect does not become\nimmediatoly apparent and plaintiff did not feel said effect or know of\nthe beginning of the continuing injury done her until several years\nfollowing her last exposure to said dangerous radioactive substances\nand the plaintiff was not apprised of the nature of her bodfly ailments\nor informed or Imew that her suffering was due to the negligence of\nthe defendants until July, 1925.\n10. By reason of the premises plaintiff became, was and is sick, sora,\nlame, disabled and crippled with continually increasing pain dnd suffer-\ning both mental and physical from the time of the consencement of her\nillness unto the present, during all which time the plaintiff underwent\nand suffered and will in the future undergo and suffer groat pain both\nmental and physical and plaintiff has been, is and will be hindored and\nprevented from transacting her lawful affairs and has been is and will\nbe deprived of divers large mins and money spent in endeavoring to be\ncured of said disability and incapacity received as aforesaid and plain-\ntiff has likewise suffered great loss in that she because of her disabil-\nity and incapacity received as aforesaid, has been unable and will be un-\nable to pursue a gainful occupation.\nPlaintiff demands against the defendant, United States Radium\nCorporation, individually, and atainst The Luminite Corporation, indiv-\nidually, and or agninst the United States Radium Corporation and The\nLuminite Corporation jointly end or against the United States Radium\nCorporation or in the alternative against the defendant The Luminite\nCorporation, One Hundred and Twenty-five Thousand ($125,000) Dollars\ndamages on the first count.\nSECOND COUNT\n1. Paragraphs 1.2 and 3 of the first count are hereby repeated\nas paragraph 1 of the second count."
}