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manner known to the defendants and unknown to the plaintiff's
intestate, entered the system and circulation of the plaintiff's
intestate, causing her great pain and suffering and a diseased
and injured condition as a result of which she died.
5.
The defendants well knew and had notice that
the plaintiff¹s intestate would become impregnated and did
become impregnated through her entire system with the substance
hereinbefore described, and deleterious to her life and health,
and furnished and used as aforesaid by the defendants, and
necessarily so by reason of the careless, negligent and
improper manner in which she was ordered, suffered and permitted
to work by the defendants.
6.
Notwithstanding the defendants' knowledge and
notice of the danger, incident to the said employment of which
the defendants well knew, and further ken that plaintiff's
intestate had no knowledge or notice of the same, the defendants
did not, at any time, inform or notify her of said dangers or
any
provide/means by which this plaintiff's intestate and others
doing similar work could avoid the danger; and in no manner
provided any device or means of overcoming the danger, neither
did they provide her with necessary and proper means and treat-
ment to overcome the disability and injury caused her in the
course of her employment.
7.
By means of the premises the plaintiff's intestate
became entirely disabled and sick in limb and body and finally
as a result of the diaability and injury hereinbefore referred
to, died on December 9,1924.
8.
Plaintiff says that the disability, injury and
subsequent death of Hazel Kuser was the direct result of the
wrongful act,acts, neglect, carelessness and default of the
defendants above named as above set forth.
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Document data
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- Core
- doc
- Type
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Context sent to Scholar
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"ocrText": "-3-\nmanner known to the defendants and unknown to the plaintiff's\nintestate, entered the system and circulation of the plaintiff's\nintestate, causing her great pain and suffering and a diseased\nand injured condition as a result of which she died.\n5.\nThe defendants well knew and had notice that\nthe plaintiff¹s intestate would become impregnated and did\nbecome impregnated through her entire system with the substance\nhereinbefore described, and deleterious to her life and health,\nand furnished and used as aforesaid by the defendants, and\nnecessarily so by reason of the careless, negligent and\nimproper manner in which she was ordered, suffered and permitted\nto work by the defendants.\n6.\nNotwithstanding the defendants' knowledge and\nnotice of the danger, incident to the said employment of which\nthe defendants well knew, and further ken that plaintiff's\nintestate had no knowledge or notice of the same, the defendants\ndid not, at any time, inform or notify her of said dangers or\nany\nprovide/means by which this plaintiff's intestate and others\ndoing similar work could avoid the danger; and in no manner\nprovided any device or means of overcoming the danger, neither\ndid they provide her with necessary and proper means and treat-\nment to overcome the disability and injury caused her in the\ncourse of her employment.\n7.\nBy means of the premises the plaintiff's intestate\nbecame entirely disabled and sick in limb and body and finally\nas a result of the diaability and injury hereinbefore referred\nto, died on December 9,1924.\n8.\nPlaintiff says that the disability, injury and\nsubsequent death of Hazel Kuser was the direct result of the\nwrongful act,acts, neglect, carelessness and default of the\ndefendants above named as above set forth."
}