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 | | During June of 2001, Dr. Maldonado visited the region that is the subject matter of this Complaint, along with a member of the Ecuadorian National Congress, to verify complaints from the population regarding the spraying of the region with fumigants dropped from airplanes. |
 | | At all relevant times, the DynCorp Defendants owed Plaintiffs, their children, and members of the class a duty to act with reasonable care, and at all relevant times, harm and/or injury to the Plaintiffs, their children, and members of the class was reasonably foreseeable if such duty of care was breached. |
 | | As a direct and proximate result of Defendants' negligent selection, hiring, retention and contracting with the pilots who sprayed toxic poison on Plaintiffs, their children, and members of the class, Plaintiffs have suffered and continue to suffer injuries entitling them to damages in amounts to be proven at trial. |
| www.laborrights.org /projects/corporate/dyncorp/dyncorpcomplaint.doc (7788 words) |
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