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"Plaintiff so carelessly and negligently conducted himself that he, by his own negligence, contributed directly and proximately to his own injuries," the lawyers for VGOD wrote

Rounding out the top five are Massachusetts (38%), New Mexico (36%) and the state of Washington (35%)

doi: 10.1046/j.1365-2222.2000.00820.x 73 HeijinkIHvan OosterhoutAKapusA

Under that definition, anything from clove cigarettes (which have been around for decades) to nicotine-free vapes would qualify

The evidence is sufficient to infer a causal relationship between parental smoking and middle ear disease in children, including acute and recurrent otitis media and chronic middle ear effusion

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