Plaintiff alleges latex sensitization and as a result suffers from asthma, shortness or breath, rhinitis, respiratory problems, tightness in the chest, dizziness, skin rashes, hives, contact dermatitis, urticaria, extreme discomfort, depression and emotional distress, all of which are or may be of a permanent continuing and life-threatening nature.
Further alleges suffering considerable mental anguish, limitation and restriction of his usual activities, pursuits and pleasures, and may suffer substantial loss or earnings and earning capacity, and has been forced to expend sums of money for medical care and treatment and will continue to be caused to expend such indefinitely into the future.
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