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3. By reason of the negligentmanner in which the defendant conducted and carried on its business as hereinabove particularly described andby reason of the general manner in which it earried on con- tinuously the business above referred to, employing and soliciting for em- ployment large numbers of persons continuously, 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 in introducing into and fixing and depositing in the body of the said decedent the substances hereinabove referred to and in causing then to come in dengerous and close proximity and contact with the body of the decedent, by reason of all of which she died. Judgment will be claimed on the second count in the sum of $75,000.00, together with costs of this suit to be taxed. The plaintiff Harold J. Weber, administrator of the estate of Louise Banle Weber, deceased, says that: THIRD COUNT 1. The plaintiff is a resident and citisen of the minici- pality of Olive Bridge, Ulster County, in the State of New York. The plain- tiff was duly appointed and has qualified as administrator of the estate of Louise Hanle Weber, such appointment having been made by the Surrogate of Essex County, New Jersey, on June 17, 1935. 2. The plaintiff repeats the allegations of paragraphs 2 to 11 inclusive of the first count. 3. For considerably more than a year prior to the time of her death, the decedent suffered much pain as a result of lesions produced by radioactive substances deposited and fixed in her body, and in addition to the pain suffered by reason of the condition of her right arn as the same developed, and the amputation thereof, the decedent suffered in other parts of her body from the effects of the said radioactive substances, and was obliged to expend and become indebted in large sums of money for medical and hospital attention and for medicines and appliances, and was prevented from attending to her usual occupations thereby producing additional

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4
Source index
0
Type
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Document data

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Type
document
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Page context
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    "ocrText": "3. By reason of the negligentmanner in which the\ndefendant conducted and carried on its business as hereinabove particularly\ndescribed andby reason of the general manner in which it earried on con-\ntinuously the business above referred to, employing and soliciting for em-\nployment large numbers of persons continuously, the defendant did in fact\nthereby create and maintain a nuisance, from which the decedent received a\ndirect and special injury by reason of the proximate and natural effect of\nsaid nuisance in introducing into and fixing and depositing in the body of\nthe said decedent the substances hereinabove referred to and in causing then\nto come in dengerous and close proximity and contact with the body of the\ndecedent, by reason of all of which she died.\nJudgment will be claimed on the second count in the sum\nof $75,000.00, together with costs of this suit to be taxed.\nThe plaintiff Harold J. Weber, administrator of the estate\nof Louise Banle Weber, deceased, says that:\nTHIRD COUNT\n1. The plaintiff is a resident and citisen of the minici-\npality of Olive Bridge, Ulster County, in the State of New York. The plain-\ntiff was duly appointed and has qualified as administrator of the estate of\nLouise Hanle Weber, such appointment having been made by the Surrogate of\nEssex County, New Jersey, on June 17, 1935.\n2.\nThe plaintiff repeats the allegations of paragraphs\n2 to 11 inclusive of the first count.\n3.\nFor considerably more than a year prior to the time\nof her death, the decedent suffered much pain as a result of lesions produced\nby radioactive substances deposited and fixed in her body, and in addition\nto the pain suffered by reason of the condition of her right arn as the\nsame developed, and the amputation thereof, the decedent suffered in other\nparts of her body from the effects of the said radioactive substances, and\nwas obliged to expend and become indebted in large sums of money for medical\nand hospital attention and for medicines and appliances, and was prevented\nfrom attending to her usual occupations thereby producing additional"
}