Reynolds v. Skelly Oil Co.

Eight separate grounds of negligence are charged in the petition as follows: (1) That the said Jay Watson was negligent in that he knew the place in which he asked the plaintiff to stand when he was fixing the tire was not a safe place to stand while doing such heavy pounding; (2) that the defendant knew the plaintiff herein was in close proximity and should have known that to strike with such force with the plaintiff so near to the tire was careless, reckless and jeopardizing the safety of his customer; (3) that the defendant knew that the hammer which he was using was old and brittle and…