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" ... injury was caused by the negligence of the defendant, and without any fault or negligence on the part of the plaintiff... "
Encyclopedia of Forms and Precedents for Pleading and Practice, at Common ... - Page 53
edited by - 1900
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The Northeastern Reporter, Volume 35

Law - 1894 - 1172 pages
...the beaten track in said road; tnat while endeavoring to keep said horse from overturning the buggy, and without any fault or negligence on the part of the plaintiff, plaintiff and said horse were precipitated into and over said ditch, whereby plaintiff's shoulder was...
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Atlantic Reporter, Volume 38

Law reports, digests, etc - 1898 - 1132 pages
...climbed upon said ladder while placed in the ordinary position necessary and convenient to do said work, and without any fault or negligence on the part of the plaintiff, and while using ordinary and reasonable care, the foot or lower end of said ladder suddenly slipped...
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The Southwestern Reporter, Volume 87

Law reports, digests, etc - 1905 - 1404 pages
...towards the said railroad track of the defendant, and that while said girder was in said position, and without any fault or negligence on the part of the plaintiff or his fellow workmen engaged with him in the said work, the said girder was struck by the said electric...
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Reports of Cases Argued and Determined in the Appellate Court of ..., Volume 6

Indiana. Appellate Court - Law reports, digests, etc - 1893 - 800 pages
...permitting the dead-woods to be and remain of uneven height on said cars, thereby rendering it very dangerous and hazardous to couple the same, which...plaintiff was earning and receiving from the defendant for Wa services the sum of two dollars per day for his said services; that the said injury rendered the...
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The Northwestern Reporter, Volume 54

Law reports, digests, etc - 1893 - 1260 pages
...that said fire spread onto and over the granary of said plaintiff, and totally destroyed the same, without any fault or negligence on the part of the plaintiff; that the granary was worth the sum of ?75; that It contained 1,200 bushels of oats, whose market value at...
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Reports of Cases Argued and Determined in the Appellate Court of ..., Volume 8

Indiana. Appellate Court - Law reports, digests, etc - 1894 - 786 pages
...the beaten track in said road; that while endeavoring to keep said horse from overturning the buggy, and without any fault or negligence on the part of the plaintiff, plaintiff and said horse were precipitated into and over said ditch, whereby plaintiff's shoulder was...
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The Pacific Reporter, Volume 37

Law reports, digests, etc - 1894 - 1148 pages
...account of the fault, carelessness, negligence, and recklessness of defendant, its agents and employes, and without any fault or negligence on the part of the plaintiff, in not using and exercising proper care and caution and skill in bracing, casing, and timbering said...
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American Negligence Cases: A Complete Collection of All Reported ..., Volume 7

Law reports, digests, etc - 1897 - 830 pages
...defendant, its servants and employees, in failing to properly secure, adjust and fasten said trapdoor and without any fault or negligence on the part of the plaintiff." In another paragraph it was alleged that the injury was caused by reason of the collapse of a trapdoor...
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The American State Reports: Containing the Cases of General Value ..., Volume 51

Abraham Clark Freeman - Law reports, digests, etc - 1896 - 1026 pages
...permitting the deadwoodi to be and remain of uneven height on said cars, thereby render ing it very dangerous and hazardous to couple the same, which...thousand dollars ($5,000); that at the time of receiving aaid injury, plaintiff was earning and receiving from the defendant for his services the sum of two...
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Reports of Cases Heard and Determined in the Appellate Division ..., Volume 27

New York (State). Supreme Court. Appellate Division - Law reports, digests, etc - 1898 - 744 pages
...the negligence of the defendant. The complaint alleges that ;' owing to the gross carelessness aud negligence of the defendant, and without any fault or negligence on the part of the said minor or this plaintiff in any wise contributing thereto," the said minor, while performing...
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