Thomas Peters, a minor, by Henry Peters, his next friend, by Ambrose
50 C. Hoover, his attorney, complains of the Western Machinery Company, a corporation, of a plea of trespass on the case:For that whereas, on to
75 wit, the eighteenth day of November, A. D. 1905, the defendant was a corporation doing business in the State of New York,100 and was then and there operating a certain factory in the city of Buffalo, County and State aforesaid, and in its said factory was then
123 and there operating a certain machine called a planing machine; and plaintiff, who was then and there a minor of to wit, eighteen years of
150 age, was then and there in the employ of said defendant as a common laborer; and plaintiff alleges that he was then and there entirely
175 ignorant of the safe operation of said machine, and utterly failed to appreciate the dangers incident to the operation of said machine, of which such
200 ignorance and lack of appreciation of such dangers the defendant then and there knew or by the exercise of ordinary care could have known. Plaintiff
225 alleges that the operation of said machine was attended with great danger of bodily injury. Plaintiff further alleges that it then and there became and
250 was the duty of the defendant not to order or require the plaintiff to leave his said work of common laborer and undertake the operation
275 of said machine without first instructing plaintiff in the safe operation of said machine and apprizing plaintiff of the dangers incident to the operation of
300 said machine. Yet the plaintiff alleges that the defendant, on the day aforesaid and by and through its servant, foreman or boss, then and there,325 negligently and carelessly ordered and commanded the plaintiff to operate said machine without first having instructed plaintiff in the safe operation of said machine, and
350 also without first having apprized plaintiff of the dangers incident to the operation of said machine; by reason whereof plaintiff alleges that he then and
375 there, while in the exercise of all due care and caution for his own safety, had one of the fingers of his right hand crushed
400 and mangled, and by reason thereof the plaintiff also became and was sick, sore, lame and disordered, and so remained for a long space of
425 time, to wit, hitherto, and by reason thereof plaintiff has been compelled to lay out, and has laid out and became liable for, divers large
450 sums of money in and about endeavoring to be cured of his said wounds and sickness, and by reason thereof plaintiff has been deprived of,475 and will in the future be deprived of, divers large gains and profits which he otherwise would have acquired from his labor.

Wherefore the plaintiff
500 says he has sustained damages in the sum of two thousand dollars, and therefore he brings his suit, etc.