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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
materials 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 deleterious
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 conduet 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 apply the said
so
paint; (c) to Anstruct 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 wern 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 afore-
said, plaintiff followed the instructions given her as aforesaid in mixing
the ingredients of the said paint and applying the same to the various sur-
faces as she was directed to do by the defendant, and during that time, she
was ignorent of the nature, character and composition of the materials fur-
nished her for the making of said luminous paint, and that the said materials
were dangerous, poisonous and deleterious to the body and health of human
beings. In fact, said materials did enter and impregnate her body to her
permanent and serious harm.
8. On account of the negligence of the defendant as set forth
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Document data
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Context sent to Scholar
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"ocrText": "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.\nThe said defendant knew or should have known that the\nmaterials 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 deleterious\nproperties of the ingredients of the said materials.\n6.\nIt was the duty of the defendant to use reasonable care:\n(a) to furnish the plaintiff with a safe place in which to conduet or carry\non the duties required of her by her employment; (b) to furnish her with\nsafe implements with which to handle the said materials and to apply the said\nso\npaint; (c) to Anstruct her in the use of the implements and the handling of\nsaid materials as to protect her from any injury by reason of the handling and\napplying of said materials and paint; (d) to wern the plaintiff of the\ndangerous, poisonous and deleterious properties of the materials used in the\nperformance of her duties and the danger to her health and person incident to\nthe handling of said materials, and the application of said paint, all of which\nsaid defendant wholly failed to perform.\n7.\nDuring the time of her employment with the defendant as afore-\nsaid, plaintiff followed the instructions given her as aforesaid in mixing\nthe ingredients of the said paint and applying the same to the various sur-\nfaces as she was directed to do by the defendant, and during that time, she\nwas ignorent of the nature, character and composition of the materials fur-\nnished her for the making of said luminous paint, and that the said materials\nwere dangerous, poisonous and deleterious to the body and health of human\nbeings. In fact, said materials did enter and impregnate her body to her\npermanent and serious harm.\n8. On account of the negligence of the defendant as set forth"
}