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OCR Page 1 of 32TO THS HONORABLY EDWIN ROBKRT WALKBR, or THE STATE
O7 NEW JERSEY.
GRACE PRYER, of the City of Orange, County of Resex
and State of Now Jersey, complainant says that:
not
1918
1. From on or about the 10th day of April, 1917, to
on Or about the lst day of Jemury, 1921, complainant was en-
ployed at the factory of the United States Radium Corporation
defendant herein. Compleinent's à employment consisted in
mixing a powder, which Gofendant Corporation supplied to
complainant, with gluo and water, with which complai nent was
likewise supplied by the defendant, into a paste of the proper
consisteney which paste complai nant then applied with a enall
camel hair brush to numerala on the dials of watches. This
operation required some ekill in the use of the brush with
4 Deny
which it was necessary to mark e fine line- 70 arder to
secure a fine point with which to draw the necessary fine
4 During
line with the brush, complanant used to point said bruah by
putting the Bame in her mouth, as she was instructed to do
Denvy.
whon she first came to the plant of the defondant and na was
customary among her co-workers during the several years dur-
ing which abe was employed at the plant of the defendant as
15
here inbeforo set forth. The brush, whon pointed by the lips,
contained amall quantities of asiá paste referred
to, some of which would remain on complainant's lips and was
6
eventually awallowed The powder heroinbefore referred to
6 Beny-
whiob wea mixed into the paste, was very light and the air
in the work room was saturated with said powder which com-
plainant breathed and which adhered to all parte of hor body
and clothing, so that upon returning home, complainent's cloth-
ing and parts of her body would be luminous in the dark.
/ nothematics
2. Complainant had no knowledge whatacever as to the
ingredients which she mixed together to form the paste herein
r
before referred to in paragraph l, Although complainent
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