Description of Event or Problem · 1
THE PLAINTIFF ALLEGES THAT DURING THE COURSE OF PLAINTIFF'S EMPLOYMENT AS AN EMERGENCY ROOM TECHNICIAN, PLAINTIFF WAS EXPOSED TO LATEX GLOVES AND LATEX ALLERGENS WHICH PLAINTIFF BELIEVES CAUSED PLAINTIFF TO BECOME ILL, INJURED AND DISABLED. PLAINTIFF ALSO ALLEGES THAT THE CUMULATIVE AND SUBSTANTIAL EXPOSURE RESULTED IN PLAINTIFF'S EXPERIENCING SEVERE ALLERGIC REACTIONS AND INJURIES INCLUDING BUT NOT LIMITED TO GENERAL ITCHING, RHINOCONJUNCTIVITIS, RESPIRATORY PROBLEMS, ASTHMA-LIKE SYMPTOMS, DYSPNEA, BRONCHITIS, DIFFICULTY BREATHING, WHEEZING, RUNNY NOSE, NASAL CONGESTION, COUGH, AND RELATED MENTAL AND EMOTIONAL DISTRESS OF A PERMANENT, WORSENING AND CONTINUING NATURE. PLAINTIFF FURTHER ALLEGES THAT IN 2000 PLAINTIFF FIRST BECAME AWARE THAT PLAINTIFF'S INJURIES AND SYMPTOMS WERE RELATED TO LATEX EXPOSURE. FURTHERMORE, PLAINTIFF ALLEGES THAT PLAINTIFF HAS SUFFERED AND WILL CONTINUE TO SUFFER CONSIDERABLE PHYSICAL INJURY, MENTAL AND EMOTIONAL ANGUISH, SEVERE LIMITATION AND RESTRICTION OF PLAINTIFF'S USUAL ACTIVITIES, PURSUITS AND PLEASURES. PLAINTIFF ALSO ALLEGES THAT PLAINTIFF HAS BEEN CAUSED TO SUFFER AND WILL CONTINUE TO SUFFER SUBSTANTIAL LOSS OF EARNINGS AND EARNING CAPACITY. PLAINTIFF FURTHER ALLEGES THAT PLAINTIFF HAS BEEN FORCED TO EXPEND SUMS OF MONEY FOR MEDICAL CARE AND TREATMENT AND WILL CONTINUE TO EXPEND SUCH SUMS INDEFINITELY INTO THE FUTURE. PLAINTIFF ALLEGES THAT PLAINTIFF HAS BEEN FORCED TO EXPEND SUMS OF MONEY FOR THE REPLACEMENT OF PLAINTIFF'S WARDROBE, AND OTHER PERSONAL AND HOUSEHOLD EFFECTS. FINALLY, THE PLAINTIFF'S SPOUSE ALLEGES THAT SPOUSE HAS BEEN DEPRIVED AND WILL BE PERMANENTLY DEPRIVED OF THE CONSORTIUM OF THE SPOUSE, INCLUDING THE PERFORMANCE OF SPOUSAL ACTS AND DUTIES, ALL TO THEIR GENERAL DAMAGE. THE PLAINTIFF'S SPOUSE ALSO ALLEGES THAT SPOUSE HAS SUFFERED AND WILL CONTINUE TO SUFFER LOSS OF CONSORTIUM, INCLUDING BUT NOT LIMITED TO, LOSS OF SERVICES, NORMAL MARITAL RELATIONS, SOCIETY, COMFORT, COMPANIONSHIP, LOVE AND AFFECTION OF SAID SPOUSE, AND HAS SUFFERED SEVERE MENTAL AND EMOTIONAL DISTRESS.