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13.
The natural and proximate result of the conduct of the
defendant was to mislead the plaintiff and to conceal from her the fact that
a cause of action arose or might arise in her favor and against the defendant
because of the latter's breaches of duty as aforesaid, until August, 1931.
14. The plaintiff charges that under the circumstances it would be
inequitable and unjust to permit the defendant to set up in answer and defense
to the action of the plaintiff now pending in the United States District Court
for the District of New Jersey, that the action is barred by the statute of
limitations of this State.
15. The plaintiff further charges that by reason of its fraudulent
conduct, the defendant has barred and estopped itself from the right to so
plead.
16. The plaintiff fears that unless the defendant is enjoined and
restrained from setting up the defenses hereinabove mentioned in the action
now pending in the United States Disctict Court for the District of New Jersey,
that the said court will sustain one or more of said defenses and thereby the
plaintiff will be denied all right of recovery of damages.
17.
The plaintiff also fears that unless in the interim and pending
the hearing of this cause and the determination of whether the defendant
should be permanently enjoined from setting up the defenses hereinabove men-
tioned in the action now pending in the United States District Court for the
District of New Jersey, the defendant be enjoined and restrained from making
any application to said court to dismiss the plaintiff's action as being
barred by the statute of limitations or for want of prosecution, the plaintiff's
rights will be impeded or destroyed.
18.
The plaintiff charges that she is entitled to the relier herein-
below prayed for by a deternination in this court of the issues of fraud and
estoppel which may be raised upon the allegations of fraud and estoppel
hereinabove set forth, and that the final hearing in this cause should be
confined to a considaration and determination of the facts relevant, pertinent
and admissable in connection with said issues.
PLAINTIFF is without adequate remedy in the courts of law
and therefore prays:-
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Context sent to Scholar
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"ocrText": "13.\nThe natural and proximate result of the conduct of the\ndefendant was to mislead the plaintiff and to conceal from her the fact that\na cause of action arose or might arise in her favor and against the defendant\nbecause of the latter's breaches of duty as aforesaid, until August, 1931.\n14. The plaintiff charges that under the circumstances it would be\ninequitable and unjust to permit the defendant to set up in answer and defense\nto the action of the plaintiff now pending in the United States District Court\nfor the District of New Jersey, that the action is barred by the statute of\nlimitations of this State.\n15. The plaintiff further charges that by reason of its fraudulent\nconduct, the defendant has barred and estopped itself from the right to so\nplead.\n16. The plaintiff fears that unless the defendant is enjoined and\nrestrained from setting up the defenses hereinabove mentioned in the action\nnow pending in the United States Disctict Court for the District of New Jersey,\nthat the said court will sustain one or more of said defenses and thereby the\nplaintiff will be denied all right of recovery of damages.\n17.\nThe plaintiff also fears that unless in the interim and pending\nthe hearing of this cause and the determination of whether the defendant\nshould be permanently enjoined from setting up the defenses hereinabove men-\ntioned in the action now pending in the United States District Court for the\nDistrict of New Jersey, the defendant be enjoined and restrained from making\nany application to said court to dismiss the plaintiff's action as being\nbarred by the statute of limitations or for want of prosecution, the plaintiff's\nrights will be impeded or destroyed.\n18.\nThe plaintiff charges that she is entitled to the relier herein-\nbelow prayed for by a deternination in this court of the issues of fraud and\nestoppel which may be raised upon the allegations of fraud and estoppel\nhereinabove set forth, and that the final hearing in this cause should be\nconfined to a considaration and determination of the facts relevant, pertinent\nand admissable in connection with said issues.\nPLAINTIFF is without adequate remedy in the courts of law\nand therefore prays:-"
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