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and the plaintiff alleges that as to the counts of negligence and nuisance
set forth in the complaint at law, the effect of the statute and its con-
struction by the courts, is to create a bar to the causes of action alleged
by the plaintiff in the action of law.
8.
Prior to the employment by the defendant of the plaintiff and
during the period of such employment, the defendant had knowlege, actual and
imputed, of the dangerous and in jurious effect of the substances mentioned
above to the human body and human tissues. The defendant knew the said facts
both from actual experience in the use of said substances and from scientific
experimentation carried on by it, and by others to its knowlege, and from
other scientific knowledge available and known to it.
9.
Notwithstanding the fact that the relationship of master and
servant existed between the defendant and the plaintiff for the period stated
in the complaint above mentioned, and that the defendant was obliged to
inform the plaintiff of all unusual risks attending her employment which were
not obvious to or discoverable by the plaintiff, and to use due care under
the circumstances which existed to supply the plaintiff with safe and adequate
methods, tools and appliances for carrying on her work, and the independent
obligations of defendant to plaintiff, the defendant fraudulently concealed
from the plaintiff facts known to it and of which it was charged with know-
ledge respecting the dangerous and injurious nature of the substances above
mentioned an hereinabove stated, and concealed in the same manner that un-
usual risks attended the employment of the plaintiff, not discoverable by or
obvious to the plaintiff in the usual discharge of her duties, and affirma-
tively represented to the plaintiff that no damage or injury would be
hazarded or suffered by her by reason of her employment in the establishment
of the defendant, or by reason of her use of the substances above mentioned
in the course of her employment, and instructed and induced her to so use
the aforesaid substances so as to cause them to be ingested in her body.
10. The plaintiff had no knowlege or notice of the dangerous and
injurious nature of the aforesaid substances as mentioned hereinabove and
those facts were not generally known at the time. The nature of the sub-
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Document data
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DTO data
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Context sent to Scholar
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"ocrText": "and the plaintiff alleges that as to the counts of negligence and nuisance\nset forth in the complaint at law, the effect of the statute and its con-\nstruction by the courts, is to create a bar to the causes of action alleged\nby the plaintiff in the action of law.\n8.\nPrior to the employment by the defendant of the plaintiff and\nduring the period of such employment, the defendant had knowlege, actual and\nimputed, of the dangerous and in jurious effect of the substances mentioned\nabove to the human body and human tissues. The defendant knew the said facts\nboth from actual experience in the use of said substances and from scientific\nexperimentation carried on by it, and by others to its knowlege, and from\nother scientific knowledge available and known to it.\n9.\nNotwithstanding the fact that the relationship of master and\nservant existed between the defendant and the plaintiff for the period stated\nin the complaint above mentioned, and that the defendant was obliged to\ninform the plaintiff of all unusual risks attending her employment which were\nnot obvious to or discoverable by the plaintiff, and to use due care under\nthe circumstances which existed to supply the plaintiff with safe and adequate\nmethods, tools and appliances for carrying on her work, and the independent\nobligations of defendant to plaintiff, the defendant fraudulently concealed\nfrom the plaintiff facts known to it and of which it was charged with know-\nledge respecting the dangerous and injurious nature of the substances above\nmentioned an hereinabove stated, and concealed in the same manner that un-\nusual risks attended the employment of the plaintiff, not discoverable by or\nobvious to the plaintiff in the usual discharge of her duties, and affirma-\ntively represented to the plaintiff that no damage or injury would be\nhazarded or suffered by her by reason of her employment in the establishment\nof the defendant, or by reason of her use of the substances above mentioned\nin the course of her employment, and instructed and induced her to so use\nthe aforesaid substances so as to cause them to be ingested in her body.\n10. The plaintiff had no knowlege or notice of the dangerous and\ninjurious nature of the aforesaid substances as mentioned hereinabove and\nthose facts were not generally known at the time. The nature of the sub-"
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