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repeated and made paragraphs 1 to 7 inclusive, of this count.
8. As a result of the handling of the said materials by the plaintiff
and the mixing and applying of the paint with the implements furnished by the
defendant in accordance with the instructions given by the defendant, plain-
tiff's body became, still is, and during the remainder of her life will be
impregnated with a dangerous, poisonous harmful and deleterious substance.
9. The nature of the said substance which has become impregnated in
the body of the plaintiff as hereinabove set forth is of such an insidious
character that it did not produce the consequential injury to the health and
body of the plaintiff hereinabove set forth until the Month of March 1930.
10. Paragraph 8 of the first count is hereby repeated and made
paragraph 10 of this count.
THIRD COUNT
1. Paragraphs 1 to 7 inclusive, of the first count are repeated and
made paragraphs 1 to 7 inchsive, of this count.
8. Paragraph 8 of the second count is hereby repeated and made
paragraph 8 of this count.
9. The said poisonous and deleterious substance and material so
introduced into the body of the plaintiff continually attacked the said plain-
tiff's body internally and continually and progressively broke the same down.
10. The nature of said attacks was such that the consequences and
effects did not become apparent, as is the usual course and order of such cases,
so that the said plaintiff did not have knowledge of the nature of her ailment
or that it was due to the negligence of the defendant or caused by her work for
the defendant as aforesaid until March 1930.
11. The said attacks described above were of a continuing, insidious
and progressive nature and did not culminate or crystallize so as to be suscep-
tible of discovery or diagnosis until March, 1930. This is all in accordance
with the medical nature of such cases.
FOURTH COUNT
1. The plaintiff James Hoare was at the times mentioned above and
still is the husband of the plaintiff Frances Tappen Hoare.
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Context sent to Scholar
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"ocrText": "repeated and made paragraphs 1 to 7 inclusive, of this count.\n8. As a result of the handling of the said materials by the plaintiff\nand the mixing and applying of the paint with the implements furnished by the\ndefendant in accordance with the instructions given by the defendant, plain-\ntiff's body became, still is, and during the remainder of her life will be\nimpregnated with a dangerous, poisonous harmful and deleterious substance.\n9. The nature of the said substance which has become impregnated in\nthe body of the plaintiff as hereinabove set forth is of such an insidious\ncharacter that it did not produce the consequential injury to the health and\nbody of the plaintiff hereinabove set forth until the Month of March 1930.\n10. Paragraph 8 of the first count is hereby repeated and made\nparagraph 10 of this count.\nTHIRD COUNT\n1. Paragraphs 1 to 7 inclusive, of the first count are repeated and\nmade paragraphs 1 to 7 inchsive, of this count.\n8. Paragraph 8 of the second count is hereby repeated and made\nparagraph 8 of this count.\n9. The said poisonous and deleterious substance and material so\nintroduced into the body of the plaintiff continually attacked the said plain-\ntiff's body internally and continually and progressively broke the same down.\n10. The nature of said attacks was such that the consequences and\neffects did not become apparent, as is the usual course and order of such cases,\nso that the said plaintiff did not have knowledge of the nature of her ailment\nor that it was due to the negligence of the defendant or caused by her work for\nthe defendant as aforesaid until March 1930.\n11. The said attacks described above were of a continuing, insidious\nand progressive nature and did not culminate or crystallize so as to be suscep-\ntible of discovery or diagnosis until March, 1930. This is all in accordance\nwith the medical nature of such cases.\nFOURTH COUNT\n1. The plaintiff James Hoare was at the times mentioned above and\nstill is the husband of the plaintiff Frances Tappen Hoare."
}