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I <br />2 <br />3 <br />4 <br />5 <br />agreement and injuries sustained by plaintiff EAS herein <br />alleged, pinintiff will be required to incur additional <br />medical expense all to his further damage In an amount not :.et <br />ascertained. Plaintiff will seek leave of the court to amend <br />this complaint to insert-the true amount thereof when ascer- <br />tained. <br />7 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />92 <br />23 <br />24 <br />25 <br />26 <br />\-DY E. THOMAS <br />Arroveire 27 ow No g7411 <br />P. 0. BOX 717 <br />.rxmaRrnr.r., C.A <br />ri".1 .5 7'17 28 <br />(2C0) )613425S <br />w 0091 340-92ss <br />THIRD CAUSE OF ACTION <br />(General Ne(littenceRgtoliarlowel <br />Plaintiff realleges and incorporates the allegations <br />set forth in paragraphs 1 through 11 hereof as though fully <br />not forth. <br />Plaintiff and defendant entered into a lease <br />agreement for the premises herein mentioned. Implied in that <br />agreement WAR the condition that the Premises were fit for the <br />purposes and intended uses of Plaintiff, including the <br />operation of Plaintiff's business and the supply and avail- <br />of drinkable and uncontaminated water for Plaintiff <br />and his employees ri the operation of his business. <br />At all times during the tenancy, Defendant had and <br />retained _control over the supply_ pf water to _Plaintiff's <br />Premises and therefore owed a duty to Plaintiff to provide <br />safe and drinkable hater to Plaintiff and his employees during <br />the tenancy..- <br />Defendant Marlowe breached its duty to provide safe <br />and drinkable water to Plaintiff, failed to perform regular <br />testing of the water to insure that same was safe and drink- <br />ALLEN VS )(MOH <br />COPLAIIT ?Oa SWIM Page. of .i4 <br />nT'A rip!cT tR'C7 ga4 TQC7—)C.P—Tri'fIN lql SqT1AqAfIAA qM1-11AHW