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NAUGLE v. PHILIP MORRIS, et. al. (PDF) 

PLAINTIFF'S MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT ADDING CLAIM FOR PUNITIVE DAMAGES
Jump to full article: (Ft. Lauderdale, FL) Sun-Sentinel, 2008-09-02

Intro:

37. As a direct and proximate result of smoking cigarettes manufactured and sold by one or more Defendants, Plaintiff suffered from one or more of the diseases and medical

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conditions described, including emphysema/COPD, which was caused by her addiction to cigarettes that contain nicotine and each of which manifested during the class period.

COUNT I: STRICT LIABILITY . . .

COUNT II: FRAUD BY CONCEALMENT . . .

COUNT III: CONSPIRACY TO COMMIT FRAUD BY CONCEALMENT . . .

COUNT IV: NEGLIGENCE . . .

COUNT V: BREACH OF EXPRESS WARRANTY . . .

COUNT VI: BREACH OF IMPLIED WARRANTY

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