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and has suffered various and severe permanent injuries
and that because of the nature of the substance with which
plaintiff was required to work, such injuries did not
manifest themselves until long after said female plaintiff
had left the employ of defendant, and that by reason of
the aforesaid, the husband of said female plaintiff has
suffered consequential damages and loss; and
Defendant having answered the said com-
plaint and having denied all allegations of negligence
therein set up, and having further set up in said answer
that the said actions of said plaintiffs, and each of them,
are barred by the Statute of Limitations of the State of
New Jersey in such case made and provided; and
Plaintiffs having filed a reply to said
answer of defendant, denying that the actions of said
plaintiffs, or either of them, are barred by the Statute of
Limitations of the State of New Jersey, and further alleging
that the said defendant, because of fraudulent conduct
upon its part in concealing from said plaintiffs that they
and each of them had a cause of action against said defend-
ant for the matters and things in said complaint set forth,
and in fraudulently representing that the said materials
with which said female plaintiff worked were not dangerous
or deleterious to health, should be estopped from pleading
said Statute of Limitations; and
Defendant having rejoined to said
replication, denying the allegations of said replication
and also setting up that the allegations of fraud set forth
in the plaintiffs* replication are not matters cognizable
in a court of law; and
The parties having agreed to submit to
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Context sent to Scholar
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"ocrText": "and has suffered various and severe permanent injuries\nand that because of the nature of the substance with which\nplaintiff was required to work, such injuries did not\nmanifest themselves until long after said female plaintiff\nhad left the employ of defendant, and that by reason of\nthe aforesaid, the husband of said female plaintiff has\nsuffered consequential damages and loss; and\nDefendant having answered the said com-\nplaint and having denied all allegations of negligence\ntherein set up, and having further set up in said answer\nthat the said actions of said plaintiffs, and each of them,\nare barred by the Statute of Limitations of the State of\nNew Jersey in such case made and provided; and\nPlaintiffs having filed a reply to said\nanswer of defendant, denying that the actions of said\nplaintiffs, or either of them, are barred by the Statute of\nLimitations of the State of New Jersey, and further alleging\nthat the said defendant, because of fraudulent conduct\nupon its part in concealing from said plaintiffs that they\nand each of them had a cause of action against said defend-\nant for the matters and things in said complaint set forth,\nand in fraudulently representing that the said materials\nwith which said female plaintiff worked were not dangerous\nor deleterious to health, should be estopped from pleading\nsaid Statute of Limitations; and\nDefendant having rejoined to said\nreplication, denying the allegations of said replication\nand also setting up that the allegations of fraud set forth\nin the plaintiffs* replication are not matters cognizable\nin a court of law; and\nThe parties having agreed to submit to"
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