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1 <br />2 <br />3 <br />4 <br />5 <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 />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />28 <br />Z THOMAS <br />ou. 27 add 144 Q744 <br />. DOX 1%7 <br />BM:Mt CA 28 - <br />) 3604788 11 <br />35. Plaintiff is informed And believes, and thereon <br />alleges that Defendants Tinware :Ind no,e s 1-50 b reac h e d t hi s <br />duty by dischareing or releasing chemicals known to the state <br />to cause cancer in humnns into rhe weter, into or onto land <br />where such chemical passes or probably will 08Ss into any <br />source of drinking water. <br />As a proximate result of the defendant's nev.lisf.ence, <br />Plaintiff has suffered general damages in an amount within the <br />jurisdiction of this court according to proof at trial. <br />As a further .nroximate 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 />business and business income in an amount within the jurisdic- <br />tion of this court Recording to proof at trial. <br />38.• As a further proximate reRult of the negligence of <br />defendant, Plaintiff has suffered illness and physical condi- <br />tions and ailments Rnd plaintiff was recuired to and did <br />employ phi:Ricians, surgeons, and other medical personnel and <br />incurred expenses therefor, and incurred additional medical <br />expense for hospital bills and other incidental medical <br />expTens, -girt° his further damage in an amount that has not <br />yet been fully ascertained, and plainLiff will s.ifek leevp to <br />amend this complaint to insert the true amount thereof when <br />ascertained. <br />39. Plaintiff is informed and believes, and thereon <br />alleges that as a proximate result of the negligence of <br />defendant and injuries sustained by plaintiff as herein <br />it.:41 4! <br />COOLAIIT Pot BUMS -- *— — • --Page 1 1 of