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1 <br />2 <br />3 <br />4 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />18 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />MY V. THOMAS <br />TTQAM4Y AT LAW <br />ANS AAT 0711411 <br />R 0.1/0X 717 <br />TIODISRIDUL CA <br />2:6";:r7:17 <br />207) $804266 <br />C. (200) 3604288 <br />27 <br />28 <br />alleged, Plaintiff will he required to incur additional <br />medical expense all to his further damage in an amount not yet <br />ascertained. Plnintiff will seek leAve of the court toamend <br />thi complaint to insert the true amount thereof when ascer- <br />tained. <br />FIFTH CAUSE OF ACTION <br />k;eneralke;luenco-Timwei <br />40. Plaintiff realleges and incorporates the allegations <br />set forth in paragraphs 1 through 11 hereof As though fully <br />set forth. <br />Plaintiff is informed and believes, and thereon <br />alleges that Defendants Tinware and Does 1-25 owed a duty to <br />Plaintiff to act reawonably in disposing of dangerous, toxic <br />and cancer causing chemicals at or about the premises occupied <br />by Tinware. <br />Plaintiff is informed and believes, and thereon <br />alleges that Defendants Tinware And noes 1-25 breached their <br />duty to Plaintiff by. discharging or relefising dangerous, toxic <br />and cancer causing chemicals into the water or onto or into <br />the land where such chemicals pass, or probably will pass into <br />the source of Plaintiff's ArinkinC water— <br />A2. As a proximate result of the defendant's negligence. <br />Plaintiff has suffered general damages in an amount within the <br />jurisdiction of this court according to proof at trial. <br />44. As a further proximate result of the negligence of <br />defendant, Plaintiff has suffered illness and Physical <br />conditions and ailments which have resulted in damage to his <br />MAO VS MIRIAM <br />COIPLAIIT ROI DAIIAGU Pago 12 of 14._ <br />tT'A it:CT tR'C7 aa4 T7—)t7—C.Tt'fIKI lql c.qT1A -4,01}1.4 wIn-r4H4,1