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and physionl from that time unto the present and during all
that time the plaintiff undervent and auffered and will in
the futuro undergo and auffer grout pain both nontal and
physical and plaintiff has been, is and will be hindered and
prevented from transscting her necessary and lawful atfairs
and has been, is and will be deprived of divers large gains
and money apent in endeuvoring to be oured of sol d disability
and incapacity received as aforesald and plaintiff hes like-
wiso suffered great loss in that she, because of her disa-
bility und incapacity received as will be unable
to pursue a gainful occupption.
Plaintiff demanda one Hundred Twonty-five Thousand
($125,000) Dollaes damages on the first count.
SECOID COUNT
1. Paragrapha 1 and 2 of the firat court are boreby
repeated as paragraph 1 of the second count.
2. During the period referred to in paragraph one
of this count pleintiff was caployed as a servant of the
defendant corporation to work in defondant's factory in
Orange aforeseid.
3. Dofen- ant fei led to provide the plaintiff with
o safe place to work but ordored and instructod the plointe
14f to handle and to be constantly in close proximity with
quantities of dangerous radiosetive gubstances,
4.
Plaintiff did not know of the dangezous nature
of the aaid radiosotive substances or their haraful offocts
upon the human body.
5. Defendant gave no warning to the plaintiff
of the dangerous nature of said radioactive substances inte
close proximity with which plaintiff was brought, but
constantly ordered and directed plaintiff to be brought into
close proximity with aaid dangerous radioactive aubstance
with the result that plaintiff was exposed to the penetrative
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Document data
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- 75721706
- Core
- doc
- Type
- document
DTO data
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Context sent to Scholar
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"ocrText": "and physionl from that time unto the present and during all\nthat time the plaintiff undervent and auffered and will in\nthe futuro undergo and auffer grout pain both nontal and\nphysical and plaintiff has been, is and will be hindered and\nprevented from transscting her necessary and lawful atfairs\nand has been, is and will be deprived of divers large gains\nand money apent in endeuvoring to be oured of sol d disability\nand incapacity received as aforesald and plaintiff hes like-\nwiso suffered great loss in that she, because of her disa-\nbility und incapacity received as will be unable\nto pursue a gainful occupption.\nPlaintiff demanda one Hundred Twonty-five Thousand\n($125,000) Dollaes damages on the first count.\nSECOID COUNT\n1. Paragrapha 1 and 2 of the firat court are boreby\nrepeated as paragraph 1 of the second count.\n2. During the period referred to in paragraph one\nof this count pleintiff was caployed as a servant of the\ndefendant corporation to work in defondant's factory in\nOrange aforeseid.\n3. Dofen- ant fei led to provide the plaintiff with\no safe place to work but ordored and instructod the plointe\n14f to handle and to be constantly in close proximity with\nquantities of dangerous radiosetive gubstances,\n4.\nPlaintiff did not know of the dangezous nature\nof the aaid radiosotive substances or their haraful offocts\nupon the human body.\n5. Defendant gave no warning to the plaintiff\nof the dangerous nature of said radioactive substances inte\nclose proximity with which plaintiff was brought, but\nconstantly ordered and directed plaintiff to be brought into\nclose proximity with aaid dangerous radioactive aubstance\nwith the result that plaintiff was exposed to the penetrative"
}