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rpmisps of Defendant which able, and further, allowed other tenants of the Premises to engage in unsafe and illegal conduct in that they discharged dangerous. toxic and cancer causIng chemicals into t.he water or uPon the land and n incurred expenses employ physicians. r4urgeons, and other medical personnel and therefor, and incurred additional medical herein defendant and injnries sustained by Plaintiff as alleged, plaintiff will be required to incur additional reached the water supply. 97. As a proximate resillt of the defendant's negligence, Plaintiff has suffered general damages in an amount within the 1 2 3 4 6 7 Jurisdiction of this cTourt according to proof at trial. a AS a further nroximate 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 reauired to and did expense for hospital hills and other incidcntal medical expenses, all to his further damage in an amount that has not yet been ftilly ascertained. and.plaintiff will seek leave to amend this complAinn to insert the true amount thereof when ascertained. Plaintiff is informec and believes, and thereon alleges that as a proximate result of the negligence of ALIA YS ULM C111PLIIIT ?Ili OHMS Page 9 of 14 9 10 11 12 13 14 71' R. 1720MAS !To...ay Ai LAW IS tee Pis 078411 P 0.1=717 MERLEGE, CA 2R 27 25 26 23 24 91 20. 21 15 16 17 18 19 CO) 380-it235 364428.8