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1 <br />2 <br />3 <br />4 <br />5 <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 />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />TIDOXAS <br />AT <br />11 074411 <br />V717 <br />z-le. CA - <br />42E4 <br />1G-488 <br />27 <br />28 <br />FIFTH CAUSE OF ACTION <br />h;inoril ge%11¢encs-Ttnwarel <br />Plaintiff realleges and incorporates the allegations <br />set forth in paragranhs 1 through 11 horpof as though fully <br />5er forth. <br />Plaintiff is infnrmed and helives, and c.hereon <br />alleges that Defendants Tinware and Does 1-25 owed a duty to <br />Plaintiff to act reasonably in disposing of dangerous, toxic <br />and cancer causing chemicals at or about the premiaes occupied <br />by Tinware. <br />Plaintiff is informed and believe..s, and thereon <br />alleges that Defendants TinwarP Anri Does 1-25 breached their <br />duty to Plaintiff bY.discharg inz or relesing dangerous, toxic <br />and cancer causing chemicals into the water or onto or into <br />the land where such chemicals nAss, or probably will pass into <br />the source of Plaintiff's drinking water.— -- <br />A. 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 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 />ALLIV VS 11111,011R <br />CUPLAIIT FOIL DMUS Page 12 of 14._._...... <br />alleged, Plaintiff will he required to incur additional <br />medical expense all to his further clammy..? in en amount not yet <br />ascertained. Plaintiff will SPP1: I PAV? of the court to amend <br />rhig complaint to insprt the true amount thereof when ascer- <br />Latned.