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and during all this peried the pleintiff, Liee Cubberley Canfield, underwent and suffered and vill in the future uniergo and suffer great pain both montal and physionl and the plaintiff, lise Cubberley Cenfield, has been, is and in the future will bo hindered and prevented frou transacting her necessary and lesful affeirs and has been, 18,0nd will be deprived of divers large grins and money spent in endeavoring to be cured of soid disability and in- capacity received 69 aforesaid. Plaintiff, line Cobberley Confield, decends One audred Thousond ($100000.00) Dollars dasages on the first count. SECOND COUNT. 1. Paragrepha 1 end 2 of the first count are horeby repested as 1 of the second counte 2. Duzing a period from on or about the let of September, 1916, until on os about the lst of February, 1918, plaintiff, Liee Cubberley Canfield, was employed as a servant of the defondent corporation to work in tha defendant in fectory first in Nowaris, and later in Orange,as aforeshid. 3. Defendent failed to provide the plaintiff, Mas Cubborley Canfield with a safe place to moric but ordered and instructed the plointiff line Cubberley Canfield, to bandle and to be constantly in close proximity tihh quantities of dangerous redioactive substancos. 4. Plaintifi, liso Cubberley Confield, did not inow of the dengezons noturo of the and redionetive substances or their haraful effocts upon the huran body. 5. Defondant gave no verning to the plaintiff, Ene Cubberley Canfield, of the dangerous nature of the and rediosetive substences into close proxinity with which plaintifi, line Cubberley Confield, was brought but constantly ordered and directed the plaintifi, lize Cubberley Confield to be brought into close proxinity with and dengerous rediosetive suo- stances, with the result thot the plaintifi, line Cubberley Canfield, was exposed to the penetrativo rays of the and redioactivo substences and the ezanationa thereof and the plaintiff, the Dubberley Confield, further ingested soid redionetive substances to the said plaintift's great dapage.

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0
Type
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Document data

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    "ocrText": "and during all this peried the pleintiff, Liee Cubberley Canfield, underwent\nand suffered and vill in the future uniergo and suffer great pain both montal\nand physionl and the plaintiff, lise Cubberley Cenfield, has been, is and\nin the future will bo hindered and prevented frou transacting her necessary\nand lesful affeirs and has been, 18,0nd will be deprived of divers large\ngrins and money spent in endeavoring to be cured of soid disability and in-\ncapacity received 69 aforesaid.\nPlaintiff, line Cobberley Confield, decends One audred\nThousond ($100000.00) Dollars dasages on the first count.\nSECOND COUNT.\n1. Paragrepha 1 end 2 of the first count are horeby repested\nas 1 of the second counte\n2. Duzing a period from on or about the let of September,\n1916, until on os about the lst of February, 1918, plaintiff, Liee Cubberley\nCanfield, was employed as a servant of the defondent corporation to work\nin tha defendant in fectory first in Nowaris, and later in Orange,as aforeshid.\n3. Defendent failed to provide the plaintiff, Mas Cubborley\nCanfield with a safe place to moric but ordered and instructed the plointiff\nline Cubberley Canfield, to bandle and to be constantly in close proximity\ntihh quantities of dangerous redioactive substancos.\n4. Plaintifi, liso Cubberley Confield, did not inow of the\ndengezons noturo of the and redionetive substances or their haraful\neffocts upon the huran body.\n5. Defondant gave no verning to the plaintiff, Ene Cubberley\nCanfield, of the dangerous nature of the and rediosetive substences into\nclose proxinity with which plaintifi, line Cubberley Confield, was brought\nbut constantly ordered and directed the plaintifi, lize Cubberley Confield\nto be brought into close proxinity with and dengerous rediosetive suo-\nstances, with the result thot the plaintifi, line Cubberley Canfield, was\nexposed to the penetrativo rays of the and redioactivo substences and\nthe ezanationa thereof and the plaintiff, the Dubberley Confield, further\ningested soid redionetive substances to the said plaintift's great dapage."
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