SITE INFORMATION AND CORRESPONDENCE_PRE 2019

Home Browse Search

Plaintiff is informed and believes, and thereon alleges that Defendants Tinware nnri Does 1-50 breached this duty by discharging or releasing chemicals known to the state to cause cancer in humans into the woter, into or onto land where such chemical PASSPS or probably will Pass into any source of drinking water. As a proximate result of the defendant's nev.liv,ence. Plaintiff has suffered general damages in an amount within the .jurisdiction of this court according to proof At trial. As a further Proximate result of the negligence of defendant, Plaintiff has suffered illness and physical conditions and ailments which have resulted in damage to his business and business income in an amount within the jurisdic- tion of this court according to proof at trial. As a further proximate result of the negligence of defendant, Plaintiff has suffered illness and physical condi- tions and ailments and plaintiff WAS required to and did employ ph,:sicians, surgeons, and other medical Personnel and incurred expenses therefor, and incurred additional medical expense for hospital bills and other incidental medical expen l1 to his further d8MaaP in an amount that has not yet been fully ascertained, And plAinLiff will seek leave to amend this complaint to insert the true amount thereof when ascertained. Plaintiff is informed and believes, and thereon alleges that as a proximate result of the negligence of aW E. THOMAS defendant and injuries sustained by plaintiff as herein woo Owl No 071411 4rrowdr. AT Law 27 ro.zx,a1 moraumasu 29 tun v! lumen 1 420g) 360-9255 * — .- coiniirr 'rot MIMS *- " --Page 11 of 1-4- -. - -. 0. (209) 360-9288 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 cj'd 17F,":7 qa4 IC=7-1CP-CIV'M STIIA -AelnArl 'RITInlAHW