The plaintiff suffered from inter alia urticaria, hand dermatitis, allergic rhinitis, itchy and watery eyes, chest congestion, and dyspnea (wheezing and asthma).
Plaintiff has been diagnosed as suffering from type-i latex allergy.
Plaintiff is at risk for suffering anaphylactic reactions when plaintiff comes into contact with many different commonly used products which contain the natural latex protein.
Plaintiff has suffered severe and irreversible latex allergy.
Plaintiff is restricted from entering any environment where plaintiff is exposed to latex protein.
Plaintiff alleges entering such environments puts plaintiff at serious risk for anaphylactic reaction.
Plaintiff must have life in constant vigilance for the presence of latex products, avoiding everyday common products that contain latex.
Plaintiff is restricted in life as to where plaintiff can go, and what plaintiff can do with life, with career, and with family.
Plaintiff finds it difficult to seek medical and dental care, and entering a non-latex safe environment in a hospital, for any purpose, is a health hazard.
Plaintiff has further suffered and will continue to suffer in the future, emotional distress, and an inability to engage in normal activities.
Plaintiff has suffered physical injuries, including but not limited to urticaria, hives, allergic rhinitis, itchy and watery eyes, and dyspnea, and other physical injuries, as well as despair, and loss of enjoyment of life, all of which are of a permanent and continuing and life threatening nature, and other damages.
Plaintiff has suffered great loss and depreciation of earning capacity and will continue to suffer same for an indefinite time in the future.
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