the safe use of said chemicals.

A THIRD CAUSE OF ACTION
FOR PUNITIVE AND EXEMPLARY DAMAGES

38. Plaintiffs reallege and incorporate by reference each and every allegation contained in the First and Second Causes of Action, as if fully set forth herein.

39. The defendants each evinced conscious disregard, or gross, reckless, and wanton disregard, for solely avaricious reasons, for the health and safety of those using their chemicals, and to their offspring, in the process of manufacturing semiconductor "wafers", "chips" and/or "boards".

A FOURTH CAUSE OF ACTION
FOR WRONGFUL DEATH

40. Plaintiffs realleges and incorporates by reference each and every allegation contained in the First, Second and Third Causes of Action, as if fully set forth herein.

41. The decedents JOSEPH CHERNANSKY, DONLEY MONROE, BEVERLY NOE, STUART POLANCHIK; JOHN REYNOLDS, III, RAYMOND J. WILKIE, JOHN E. WILLIAMS; DOROTHY KOVALYK; ROBERT CAHILL; KIMBERLY SCOTT CASSELL; GREGORY FORSHEY; MARTHA REED ESPARO, THOMAS GILBERT and GERALD HARRIS suffered wrongful death as a result of said contact and exposure to said chemicals.

42. The acts, omissions, and conduct of defendants, and