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The claims are in Amalia Diaz Torres' application to amend her lawsuit she first filed in 2007.
Since then, the case was moved from district to federal court.
Attorneys for Torres filed the new motion Tuesday.
Her proposed complaint claims that none of Cintas' training programs addressed any of the issues that led to the death of Eleazar Torres-Gomez in March 2007.
Torres-Gomez had climbed onto a slow-moving conveyor to clear a jam of wet laundry and fell into a 300-degree industrial dryer.
The complaint claims the company encouraged workers to climb onto conveyors to push items into the dryers to meet production goals.
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