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stances ingested into the body of the plaintiff is such that the fact and effect of such ingestion are not manifested or made known to the individual until many years thereafter, and in fact the plaintiff had no knowledge or notice of the true facts respecting the ingestion into and injury to her body by these substances and the effects thereof until the arly part of 1935. Relying upon the representations above stated and mislead by the concealment above mentioned, the plaintiff took up and carried on her employment for the period stated. The action of the plaintiff in doing so was the result of fraudulent representation, conscious, wilful concealment, and conduct in- tended to mislead the plaintiff and to conceal from her the true facts known to the defendant and with which the defendant was charged with knowledge, re- specting her employment to apply the substances above stated to the products manufactured by the defendant. 11. The plaintiff charges in addition that the defendant was under a. duty to disclose the facts hereinabove mentioned and to use due care as hereinabove mentioned in paragraph nine, which it failed to perform and that in addition, it, by its conduct, took an undue and uneonscientious ad- vantage of theplaintiff by and independent of the failure to perform those duties, and further, concealed facts from the plaintiff to induce her to take up and continue her employment, and concealed from her knowledge that a cause of action would, or might arise in favor of the plaintiff against the defendant, and so mislead her as to cause her not to institute legal proceedings based upon said cause of action until many years after the cessation of her employment. 12. The naturel and proximate result of the conduct of the defend- ant was to mislead the plaintiff and to conceal from her the fact that a cause of action arose or might arise in her favor and against the defendant because of the latter's breaches of duty as apresaid, until 1935. 13. The plaintiff charges that under the circumstances it would be inequitable and unjust to permit the defendant to set up in defense to the action of the plaintiff now pending in the United States District Court for the District of New Jersey, that the action is barred by the statute of limitations of this State, the defendant being chargeable with

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0
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Document data

ID
75729062
Core
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Type
document
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Document identity
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Page context
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    "ocrText": "stances ingested into the body of the plaintiff is such that the fact and\neffect of such ingestion are not manifested or made known to the individual\nuntil many years thereafter, and in fact the plaintiff had no knowledge or\nnotice of the true facts respecting the ingestion into and injury to her\nbody by these substances and the effects thereof until the arly part of 1935.\nRelying upon the representations above stated and mislead by the concealment\nabove mentioned, the plaintiff took up and carried on her employment for the\nperiod stated. The action of the plaintiff in doing so was the result of\nfraudulent representation, conscious, wilful concealment, and conduct in-\ntended to mislead the plaintiff and to conceal from her the true facts known\nto the defendant and with which the defendant was charged with knowledge, re-\nspecting her employment to apply the substances above stated to the products\nmanufactured by the defendant.\n11.\nThe plaintiff charges in addition that the defendant was under\na. duty to disclose the facts hereinabove mentioned and to use due care as\nhereinabove mentioned in paragraph nine, which it failed to perform and\nthat in addition, it, by its conduct, took an undue and uneonscientious ad-\nvantage of theplaintiff by and independent of the failure to perform those\nduties, and further, concealed facts from the plaintiff to induce her to\ntake up and continue her employment, and concealed from her knowledge that\na cause of action would, or might arise in favor of the plaintiff against\nthe defendant, and so mislead her as to cause her not to institute legal\nproceedings based upon said cause of action until many years after the\ncessation of her employment.\n12.\nThe naturel and proximate result of the conduct of the defend-\nant was to mislead the plaintiff and to conceal from her the fact that a\ncause of action arose or might arise in her favor and against the defendant\nbecause of the latter's breaches of duty as apresaid, until 1935.\n13.\nThe plaintiff charges that under the circumstances it would\nbe inequitable and unjust to permit the defendant to set up in\ndefense to the action of the plaintiff now pending in the United States\nDistrict Court for the District of New Jersey, that the action is barred by\nthe statute of limitations of this State, the defendant being chargeable with"
}