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15. This action is brought within two yeats
rs next
after the death of plaintiff's decedent.
JUDGMENT will be claimed on the First Count in
favor of the plaintiff and against the defendant in the sum of
one Hundred Thousand ($100000.00) Dollars together with costs
of this suit to be taxed.
SECOND COUNT
1. Plaintiff repeats the allegations contained
in paragraphs 1 to 11 inclusive, of the First Count.
2. By reason of the negligent manner in which
the defendant conducted and carried on its business as herein-
above particularly described and by reason of the general manner
in which it carried on continuously the business above referred
to, the defendant did in fact thereby create and maintain a
nuisance, from which the decedent received a direct and special
injury by reason of the proximate and natural effect of said
nuisance mintroducing into the body of the said decedent the
substances hereinabove referred to and in causing them to come
in dangerous and close proximity and contact with the body of
the decedent.
3. Plaintiff repeats the allegations contained
in paragraphs 12 to 15 inclusive, of the First Count.
JUDGMENT will be claimed on: the Segond Count in
favor of the plaintiff and against the defendant in the sum of
One Hundred Thousand ($100,000.00) Dollars together with costs
of this suit to be taxed.
The plaintiff Vincent P. La Porte, residing in
the City of Newark, County of Essex and State of New Jersey,
says that:
-4-
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"ocrText": "15. This action is brought within two yeats\nrs next\nafter the death of plaintiff's decedent.\nJUDGMENT will be claimed on the First Count in\nfavor of the plaintiff and against the defendant in the sum of\none Hundred Thousand ($100000.00) Dollars together with costs\nof this suit to be taxed.\nSECOND COUNT\n1. Plaintiff repeats the allegations contained\nin paragraphs 1 to 11 inclusive, of the First Count.\n2. By reason of the negligent manner in which\nthe defendant conducted and carried on its business as herein-\nabove particularly described and by reason of the general manner\nin which it carried on continuously the business above referred\nto, the defendant did in fact thereby create and maintain a\nnuisance, from which the decedent received a direct and special\ninjury by reason of the proximate and natural effect of said\nnuisance mintroducing into the body of the said decedent the\nsubstances hereinabove referred to and in causing them to come\nin dangerous and close proximity and contact with the body of\nthe decedent.\n3. Plaintiff repeats the allegations contained\nin paragraphs 12 to 15 inclusive, of the First Count.\nJUDGMENT will be claimed on: the Segond Count in\nfavor of the plaintiff and against the defendant in the sum of\nOne Hundred Thousand ($100,000.00) Dollars together with costs\nof this suit to be taxed.\nThe plaintiff Vincent P. La Porte, residing in\nthe City of Newark, County of Essex and State of New Jersey,\nsays that:\n-4-"
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