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2.
The plaintiff is the husband of Catherine Connolly, who is the
plaintiff in the first count, and has been such since the year 1932, since
which date the plaintiff and his said wife cohabited as hushand wife.
3.
By reason of the premises, the plaintiff was obliged to pay for
and incur obligations for medical and hospital treatment in an effort to eure
and relieve the injuries of his wife, as alleged in the action at law, and
plaintiff was likewise obliged to expend large sums of money for the per-
formance of household services ordinarily performed by his wife and which she
was rendered incapable of performing by reason of her aforesaid injuries, and
the plaintiff was deprived of the comfort, aid and affection of his wife for
a long period of time by reason of the aforesaid injuries; and plaintiff will
in the future suffer damages of the nature hereinabove set forth and also by
reason of the fact that his said wife has been and is, and will continue to
be unable to conceive and bear children, for all of which damages the plaintiff
seeks to recover against the defendant in the action now pending at law.
4.
The plaintiff repeats for himself the allegations of paragraph
7 of the first count.
5.
The plaintiff repeats for himself the allegations of paragraphs
1, 2 and 3 of the first count.
6.
The plaintiff alleges that by reason of the premises, he is en-
titled to the same relief as is prayed for in the first count, for the same
reasons as are stated in the first count.
Plaintiff is without adequate remedy in the courts of law
and therefore prays:-
1.
The plaintiff repeats for himself the prayers of the first count.
Attorneys of Plaintiffs.
Of Gounsel.
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Document data
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Context sent to Scholar
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"ocrText": "2.\nThe plaintiff is the husband of Catherine Connolly, who is the\nplaintiff in the first count, and has been such since the year 1932, since\nwhich date the plaintiff and his said wife cohabited as hushand wife.\n3.\nBy reason of the premises, the plaintiff was obliged to pay for\nand incur obligations for medical and hospital treatment in an effort to eure\nand relieve the injuries of his wife, as alleged in the action at law, and\nplaintiff was likewise obliged to expend large sums of money for the per-\nformance of household services ordinarily performed by his wife and which she\nwas rendered incapable of performing by reason of her aforesaid injuries, and\nthe plaintiff was deprived of the comfort, aid and affection of his wife for\na long period of time by reason of the aforesaid injuries; and plaintiff will\nin the future suffer damages of the nature hereinabove set forth and also by\nreason of the fact that his said wife has been and is, and will continue to\nbe unable to conceive and bear children, for all of which damages the plaintiff\nseeks to recover against the defendant in the action now pending at law.\n4.\nThe plaintiff repeats for himself the allegations of paragraph\n7 of the first count.\n5.\nThe plaintiff repeats for himself the allegations of paragraphs\n1, 2 and 3 of the first count.\n6.\nThe plaintiff alleges that by reason of the premises, he is en-\ntitled to the same relief as is prayed for in the first count, for the same\nreasons as are stated in the first count.\nPlaintiff is without adequate remedy in the courts of law\nand therefore prays:-\n1.\nThe plaintiff repeats for himself the prayers of the first count.\nAttorneys of Plaintiffs.\nOf Gounsel."
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