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4. The materials used in making said luminous paint and the
implements 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.
5. The said defendant knew or should have known that the ma-
terials furnished to the plaintiff in the performance of her duties as
aforesaid contained substances which were dangerous, poisonous and dele-
terious to the body and health of the plaintiff, and knew or should have
known that the method and manner in which the defendant instructed the
plaintiff to use and apply said materials and paint were so devised as to
negligently expose the plaintiff to the dangerous, poisonous and deleter-
ious properties of the ingredients of the said materials.
6. It was the duty of the defendant to use reasonable care:
(a) to furnish the plaintiff with a safe place in which to conduct or
carry on the duties required of her by her employment; (b) to furnish
her with safe implements with which to handle the said materials and to ap-
ply the said paint; (c) to so instruct her in the use of the implements
and the handling of said materials as to protect her from any injury by
reason of the handling and applying of said materials and paint; (d) to
warn the plaintiff of the dangerous, poisonous and deleterious properties
of the materials used in the performance of her duties and the danger to
her health and person incident to the handling of said materials and the
application of said paint, all of which said defendant wholly failed to
perform.
7. During the time of her employment with the defendant as
aforesaid, plaintiff followed the instructions given her as aforesaid in
mixing the ingredients of the said paint and applying the same to the var-
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Document data
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Context sent to Scholar
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"ocrText": "4. The materials used in making said luminous paint and the\nimplements employed in mixing and applying said paint were furnished by\nthe defendant 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.\n5. The said defendant knew or should have known that the ma-\nterials furnished to the plaintiff in the performance of her duties as\naforesaid contained substances which were dangerous, poisonous and dele-\nterious to the body and health of the plaintiff, and knew or should have\nknown that the method and manner in which the defendant instructed the\nplaintiff to use and apply said materials and paint were so devised as to\nnegligently expose the plaintiff to the dangerous, poisonous and deleter-\nious properties of the ingredients of the said materials.\n6. It was the duty of the defendant to use reasonable care:\n(a) to furnish the plaintiff with a safe place in which to conduct or\ncarry on the duties required of her by her employment; (b) to furnish\nher with safe implements with which to handle the said materials and to ap-\nply the said paint; (c) to so instruct her in the use of the implements\nand the handling of said materials as to protect her from any injury by\nreason of the handling and applying of said materials and paint; (d) to\nwarn the plaintiff of the dangerous, poisonous and deleterious properties\nof the materials used in the performance of her duties and the danger to\nher health and person incident to the handling of said materials and the\napplication of said paint, all of which said defendant wholly failed to\nperform.\n7. During the time of her employment with the defendant as\naforesaid, plaintiff followed the instructions given her as aforesaid in\nmixing the ingredients of the said paint and applying the same to the var-"
}