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adequate tools and appliances and to instruet the plaintiff in a reasonably safe and proper method of handling the said liquid compounds and the handling and forning & the brushes used to apply the said liquid compounds to the diels of tinopieces. 6. The defendant, knowing woll the dangerous nature of the liquid compounds herinbefore mentioned, and having employed the said sub- stances for many years prior to 1917 in carrying on its business, negligently and carelessly supplied the plaintiff with inadequate and unsafe tools and appliances and general working conditions for the carrying on of the duties assigned to her by the defendant, and negligently end carolessly omitted and failed to supply the plaintiff with safe and adequate tools and appliances and working conditions for earrying on hor work, and negligently and care- lessly failed to use reasonable care to varn the plaintiff of the dengerous nature of the materials with which she was working end of the unusual risks attending her employment, of all of which she was wholly ignorent, and negligently and carelesaly permitted the said dangerous substances end con- pounds to be in and about the place where the plaintiff was working, and where she was obliged to come into contact with the same, so that the poison there- from would enter her system, be conveyed to the bonea and other parts of her body, causing her grest injury, temporary and permanent disability, pain end suffering. 7. As the proximate result of the soid megligence and care- lessness, the substances, hereinabove mentioned, escaped and thereby and by other means eane into close proximity and contact with the person of the plaintifr who was exposed to the natural and inhorent effects of the said substances, and thereby the some becano lodged in and about her body and the tissues thereof. 8. The nature of the severnl substances introduced into the pleintiff's body is such that they continue to remain potent and active for meny years and produce, by thoir inherent natural properties, destructive effects upon haman bones, tissues and other portions of the body. 9. In or about the month of February, 1933, the fact of the introduction of the aforescia substances into the body of the plaintiff

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Type
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    "ocrText": "adequate tools and appliances and to instruet the plaintiff in a reasonably\nsafe and proper method of handling the said liquid compounds and the handling\nand forning & the brushes used to apply the said liquid compounds to the diels\nof tinopieces.\n6. The defendant, knowing woll the dangerous nature of the\nliquid compounds herinbefore mentioned, and having employed the said sub-\nstances for many years prior to 1917 in carrying on its business, negligently\nand carelessly supplied the plaintiff with inadequate and unsafe tools and\nappliances and general working conditions for the carrying on of the duties\nassigned to her by the defendant, and negligently end carolessly omitted and\nfailed to supply the plaintiff with safe and adequate tools and appliances\nand working conditions for earrying on hor work, and negligently and care-\nlessly failed to use reasonable care to varn the plaintiff of the dengerous\nnature of the materials with which she was working end of the unusual risks\nattending her employment, of all of which she was wholly ignorent, and\nnegligently and carelesaly permitted the said dangerous substances end con-\npounds to be in and about the place where the plaintiff was working, and where\nshe was obliged to come into contact with the same, so that the poison there-\nfrom would enter her system, be conveyed to the bonea and other parts of her\nbody, causing her grest injury, temporary and permanent disability, pain end\nsuffering.\n7. As the proximate result of the soid megligence and care-\nlessness, the substances, hereinabove mentioned, escaped and thereby and by\nother means eane into close proximity and contact with the person of the\nplaintifr who was exposed to the natural and inhorent effects of the said\nsubstances, and thereby the some becano lodged in and about her body and the\ntissues thereof.\n8. The nature of the severnl substances introduced into the\npleintiff's body is such that they continue to remain potent and active for\nmeny years and produce, by thoir inherent natural properties, destructive\neffects upon haman bones, tissues and other portions of the body.\n9. In or about the month of February, 1933, the fact of\nthe introduction of the aforescia substances into the body of the plaintiff"
}