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THE STATE OF NEW JERSEY:
TO
UNITED STATES RADION CORPORATION,
a corporation of the State of
Delaware, You are susmoned to enser
the annexed complaint of Nice Cubberly
Cenfield and Raymond Canfield in an
action-st-law in the New Jersey
Supreme Court. AND TAKE NOTICE
that unless you file your enswer to
said complaint with the Clerk of the New Jorsey Suprome Court at Trenton,
New Jersey, within twenty days efter the service upon you of this writ
and the annexed complaint, the plaintiffs any proceed in the suit and
judgment may be entered against you.
WITNESS, HONORABLE WILLIAM S. SUMMERE, Chief Justice of the
Supreme Court at Trenton, New Jersey, this 26th day of October, 1928.
(signed) Potter & Berry
(signed) Fred. L. Bloodgood
Attorneys
Clerk
11
NEW JERSEY SUPREME COURT
ESSEX COUNTY.
MAE CUBBERLEY CANFIELD, and
:
RAYMOND CANFIELD,
Plaintiffs,
:
-vs-
:
UNITED STATES RADIUM CORPORA-
i
TION, a corporation of the
State of Delaware,
:
Action-At-Law
Defendant.
:
COMPLAINT.
Plaintiffs, Mae Cubberley Canfield and Raymond Canfield,
residing in the City of Newark, County of Essex and State of New Jersey,
say that:
1. From September 1,1916 to March 1,1918, the defendant
United States Radium Corporation was 8 corporation engaged in the
extraction and manufacture of radioactive substances and the manufacture
of products of said redioactive substances for commercial purposes,
having its principal place of business, first, on Third Street, in the City
of Newark, County of Essex and State of New Jersey, and subsequently at
the corner of Alden and High Streets, in the City of Orange, County of
Essex and State of New Jersey.
2. Said radioactive substances, which were radium,
mesothorium and thorium-x, are highly dangerous substances and injurious
to the human body when brought into close proximity therewith as those in
charge of the defendent's operations well knew.
3. The defendant, well knowing the dangerous nature of the
said redioactive substances, failed to keep the size in control but was
negligent in allowing the said dangerous substances to escape and come
within close proximity with the person of the plaintiff, lise Cubberly
Canfield, where the said plaintiff was lawfully entitled to be, and the
said defendant was negligent in that it carelessly and negligently placed
said substances so that the plaintiff, Mae Cubberly Canfield, was exposed
to the penetrative rays of the said substances, inhaled the dust of the
said radioactive substances and the emanations thereof and ingested the
same to the said plaintiff's great damage.
4. Plaintiff, Mae Cubberley Canfield, was not informed or
warned and had no knowledge of the nature of the said dangerous radio-
active substances into close proximity with which she was by the defendent's
negligence brought.
5. Plaintiff, Mae Cubberley Canfield, was exposed to said
radioactive substances for the greater part of the day time during a
period of time from on or about the first day of September, 1916, to on or
about the first day of February, 1918.
6. By reason of the defendant's negligence as hereinbefore
set forth in paragraph 3 of this count, the body of the plaintiff, Mae
Cubberley Canfield, became impregnated with said radioactive substances.
7. Said radioactive substances so introduced into the
system of the plaintiff, Mae Cubberley Canfield, still continue to bombard
said plaintiff's body internally and continually attack and break down the
said plaintiff's tissues and body substance, causing the said plaintiff,
Mae Cubberley Canfield, thereby great pain and suffering both mental and
physical.
8. The effect of the introduction of the said radio-active
substances into the human body is such as not to beco immediately appar-
ent and plaintiff, Mae Cubberley Canfield, did not feel said effects or know of
the beginning of the continuing injury done to her until several years
following her last exposure to said dangerous radioactive substances and
plaintiff, Mae Cubberley Canfield, was not apprised of the nature of her
bodily ailments or informed or knew that her suffering was due to the
negligence of the defendant until on or about the 15th of June, 1928.
9. By reason of the premises plaintiff became, was and is
sick, sore, lame and disabled and crippled and has so remained for at long
space of time, becoming ill on or about the 15th of November 1926, with
continually increasing pain and suffering both mental and physical from
the time of the first onset of her illness unto the present time,
and during all this period the plaintiff, lise Cubberley Canfield, underwent
and suffered and will in the future undergo and suffer great pain both mental
and physical and the plaintiff, lise Cubberley Cenfield, has been, is and
in the future will be hindered and prevented from transacting her necessary
and lawful affairs and has been, is,end will be deprived of divers large
goins and money spent in endeavoring to be cured of said disability and in-
capacity received as aforessid.
Plaintiff, line Cubberley Confield, demands One Hundred
Thousand ($100000.00) Dollars damages on the first count.
SECOND COUNT.
1. Paragraphs 1 and 2 of the first count are hereby repeated
as paragraph 1 of the second count.
2. During a period from on or about the 1st of September,
1916, until on or about the 1st of February,1918, plaintiff, line Cubberley
Canfield, was employed as a servant of the defendent corporation to work
in the defendent's fectory first in Newark, and later in Orange,as aforessid.
3. Defendent failed to provide the plaintiff, Mae Cubberley
Canfield with a safe place to work but ordered and instructed the plaintiff
lise Cubberley Canfield, to handle and to be constantly in close proximity
tibh quantities of dengerous redionctive substances.
4. Plaintiff, llao Cubberley Confield, did not know of the
dangerous nature of the said redionctive substances or their harmful
effects upon the bunna body.
5. Defendent gave no warning to the plaintiff, Mae Cubberley
Confield, of the dangerous nature of the and redioactive substances into
close proximity with which plaintiff, line Cubberley Confield, was brought
but constantly ordered and directed the plaintiff, lise Cubberley Confield
to be brought into close proximity with said dangerous redioactive sub-
stances, with the result that the plaintiff, line Cubberley Canfield, was
exposed to the penetrative rays of the said redioactive substances and
the emanations thereof end the plaintiff, lise Dubberley Confield, further
ingested said redioactive substances to the said plaintiff's great damage.
6. Plaintiff, line Cubborley Canfield, repeats paragraphs
6,7 and 8 of the first count as paragraph 6 of the second count.
7. Às a result of the said introduction of the said don-
gerous redioactive substances into the body of the plaintiff, lise Cubberley
Canfield, and the defendant's neglect to provide a safe place for the said
plaintiff to work, and of defendant's neglect to warn the said plaintiff of
the dangerous nature of the said radionctive substances plaintiff, line
Cubberley Cenfield, has become sick, sore, lane and disabled and has suf-
fored, still suffers and will continue to suffer great pain both mental and
physical and has been prevented and will be prevented from pursuing and
transacting her leaful business and plaintiff, lise Cubberley Cenfield, has
likewise been compelled and will be in the future compelled to outlay and
expend great sums of noney in on endeavor to be cured of said disability
and incapacity received as aforessid.
Plaintiff, lise Cubberley Canfield, demands One Hundred
Thousand ($100000.00) Dollars damages on the second count.
THIRD COUNT
1. The plaintiff, Reymond Canfield, repeats the allega-
tions of paragraphs 1 to 9 inclusive of the first count and paragraphs 1
to 7 inclusive of the second count as paragraph 1 of the third count.
2. The Plaintiff, lise Cubberley Canfield, mentioned in
the first and second counts of this complaint is the wife of the plaintiff,
Reymond Cenfield.
3. By reason of the defendent's negligence as set out in
the first and second counts of this complaint, the said line Cubberley
Canfield sustained the injuries as set out in the first and second counts
and, in consequence of said injuries, the plaintiff Raymond Canfield,
the services of his s id wife and in the future will be deprived of the
services of his said wife and has in the past and will in the future be
deprived of the comfort and aid of her society and has been and in the
future will be compelled to lay out and expend large sums of money for
doctor bills and authorized in or endeavor to treat and cure his gold wife of
her injuries.
Plaintiff, Raymond Cenfield, demands Twenty-five Thousand
($25000.00) Dollars damages on the third count.
(Signed) Potter & Berry
Attorneys of plaintiffs
NEW JERSEY SUPREME COURT
ESSEX COUNTY.
MAE CUBBERLEY CANFIELD AND
RAYMOND CANFIELD,
Plaintiffs,
-VS-
UNITED STATES RADIUM CORPORATION,
a corporation of the State of
Delaware,
Defendant,
Due and legal service of a copy
of the within Summons and Complaint
is hereby acknowledged this
day of October, 1928.
Agent of the United States
Radium Corporation
Law Offices
POTTER AND BERRY
60 Park Place
Newark, N.J.
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"ocrText": "THE STATE OF NEW JERSEY:\nTO\nUNITED STATES RADION CORPORATION,\na corporation of the State of\nDelaware, You are susmoned to enser\nthe annexed complaint of Nice Cubberly\nCenfield and Raymond Canfield in an\naction-st-law in the New Jersey\nSupreme Court. AND TAKE NOTICE\nthat unless you file your enswer to\nsaid complaint with the Clerk of the New Jorsey Suprome Court at Trenton,\nNew Jersey, within twenty days efter the service upon you of this writ\nand the annexed complaint, the plaintiffs any proceed in the suit and\njudgment may be entered against you.\nWITNESS, HONORABLE WILLIAM S. SUMMERE, Chief Justice of the\nSupreme Court at Trenton, New Jersey, this 26th day of October, 1928.\n(signed) Potter & Berry\n(signed) Fred. L. Bloodgood\nAttorneys\nClerk\n11\nNEW JERSEY SUPREME COURT\nESSEX COUNTY.\nMAE CUBBERLEY CANFIELD, and\n:\nRAYMOND CANFIELD,\nPlaintiffs,\n:\n-vs-\n:\nUNITED STATES RADIUM CORPORA-\ni\nTION, a corporation of the\nState of Delaware,\n:\nAction-At-Law\nDefendant.\n:\nCOMPLAINT.\nPlaintiffs, Mae Cubberley Canfield and Raymond Canfield,\nresiding in the City of Newark, County of Essex and State of New Jersey,\nsay that:\n1. From September 1,1916 to March 1,1918, the defendant\nUnited States Radium Corporation was 8 corporation engaged in the\nextraction and manufacture of radioactive substances and the manufacture\nof products of said redioactive substances for commercial purposes,\nhaving its principal place of business, first, on Third Street, in the City\nof Newark, County of Essex and State of New Jersey, and subsequently at\nthe corner of Alden and High Streets, in the City of Orange, County of\nEssex and State of New Jersey.\n2. Said radioactive substances, which were radium,\nmesothorium and thorium-x, are highly dangerous substances and injurious\nto the human body when brought into close proximity therewith as those in\ncharge of the defendent's operations well knew.\n3. The defendant, well knowing the dangerous nature of the\nsaid redioactive substances, failed to keep the size in control but was\nnegligent in allowing the said dangerous substances to escape and come\nwithin close proximity with the person of the plaintiff, lise Cubberly\nCanfield, where the said plaintiff was lawfully entitled to be, and the\nsaid defendant was negligent in that it carelessly and negligently placed\nsaid substances so that the plaintiff, Mae Cubberly Canfield, was exposed\nto the penetrative rays of the said substances, inhaled the dust of the\nsaid radioactive substances and the emanations thereof and ingested the\nsame to the said plaintiff's great damage.\n4. Plaintiff, Mae Cubberley Canfield, was not informed or\nwarned and had no knowledge of the nature of the said dangerous radio-\nactive substances into close proximity with which she was by the defendent's\nnegligence brought.\n5. Plaintiff, Mae Cubberley Canfield, was exposed to said\nradioactive substances for the greater part of the day time during a\nperiod of time from on or about the first day of September, 1916, to on or\nabout the first day of February, 1918.\n6. By reason of the defendant's negligence as hereinbefore\nset forth in paragraph 3 of this count, the body of the plaintiff, Mae\nCubberley Canfield, became impregnated with said radioactive substances.\n7. Said radioactive substances so introduced into the\nsystem of the plaintiff, Mae Cubberley Canfield, still continue to bombard\nsaid plaintiff's body internally and continually attack and break down the\nsaid plaintiff's tissues and body substance, causing the said plaintiff,\nMae Cubberley Canfield, thereby great pain and suffering both mental and\nphysical.\n8. The effect of the introduction of the said radio-active\nsubstances into the human body is such as not to beco immediately appar-\nent and plaintiff, Mae Cubberley Canfield, did not feel said effects or know of\nthe beginning of the continuing injury done to her until several years\nfollowing her last exposure to said dangerous radioactive substances and\nplaintiff, Mae Cubberley Canfield, was not apprised of the nature of her\nbodily ailments or informed or knew that her suffering was due to the\nnegligence of the defendant until on or about the 15th of June, 1928.\n9. By reason of the premises plaintiff became, was and is\nsick, sore, lame and disabled and crippled and has so remained for at long\nspace of time, becoming ill on or about the 15th of November 1926, with\ncontinually increasing pain and suffering both mental and physical from\nthe time of the first onset of her illness unto the present time,\nand during all this period the plaintiff, lise Cubberley Canfield, underwent\nand suffered and will in the future undergo and suffer great pain both mental\nand physical and the plaintiff, lise Cubberley Cenfield, has been, is and\nin the future will be hindered and prevented from transacting her necessary\nand lawful affairs and has been, is,end will be deprived of divers large\ngoins and money spent in endeavoring to be cured of said disability and in-\ncapacity received as aforessid.\nPlaintiff, line Cubberley Confield, demands One Hundred\nThousand ($100000.00) Dollars damages on the first count.\nSECOND COUNT.\n1. Paragraphs 1 and 2 of the first count are hereby repeated\nas paragraph 1 of the second count.\n2. During a period from on or about the 1st of September,\n1916, until on or about the 1st of February,1918, plaintiff, line Cubberley\nCanfield, was employed as a servant of the defendent corporation to work\nin the defendent's fectory first in Newark, and later in Orange,as aforessid.\n3. Defendent failed to provide the plaintiff, Mae Cubberley\nCanfield with a safe place to work but ordered and instructed the plaintiff\nlise Cubberley Canfield, to handle and to be constantly in close proximity\ntibh quantities of dengerous redionctive substances.\n4. Plaintiff, llao Cubberley Confield, did not know of the\ndangerous nature of the said redionctive substances or their harmful\neffects upon the bunna body.\n5. Defendent gave no warning to the plaintiff, Mae Cubberley\nConfield, of the dangerous nature of the and redioactive substances into\nclose proximity with which plaintiff, line Cubberley Confield, was brought\nbut constantly ordered and directed the plaintiff, lise Cubberley Confield\nto be brought into close proximity with said dangerous redioactive sub-\nstances, with the result that the plaintiff, line Cubberley Canfield, was\nexposed to the penetrative rays of the said redioactive substances and\nthe emanations thereof end the plaintiff, lise Dubberley Confield, further\ningested said redioactive substances to the said plaintiff's great damage.\n6. Plaintiff, line Cubborley Canfield, repeats paragraphs\n6,7 and 8 of the first count as paragraph 6 of the second count.\n7. Às a result of the said introduction of the said don-\ngerous redioactive substances into the body of the plaintiff, lise Cubberley\nCanfield, and the defendant's neglect to provide a safe place for the said\nplaintiff to work, and of defendant's neglect to warn the said plaintiff of\nthe dangerous nature of the said radionctive substances plaintiff, line\nCubberley Cenfield, has become sick, sore, lane and disabled and has suf-\nfored, still suffers and will continue to suffer great pain both mental and\nphysical and has been prevented and will be prevented from pursuing and\ntransacting her leaful business and plaintiff, lise Cubberley Cenfield, has\nlikewise been compelled and will be in the future compelled to outlay and\nexpend great sums of noney in on endeavor to be cured of said disability\nand incapacity received as aforessid.\nPlaintiff, lise Cubberley Canfield, demands One Hundred\nThousand ($100000.00) Dollars damages on the second count.\nTHIRD COUNT\n1. The plaintiff, Reymond Canfield, repeats the allega-\ntions of paragraphs 1 to 9 inclusive of the first count and paragraphs 1\nto 7 inclusive of the second count as paragraph 1 of the third count.\n2. The Plaintiff, lise Cubberley Canfield, mentioned in\nthe first and second counts of this complaint is the wife of the plaintiff,\nReymond Cenfield.\n3. By reason of the defendent's negligence as set out in\nthe first and second counts of this complaint, the said line Cubberley\nCanfield sustained the injuries as set out in the first and second counts\nand, in consequence of said injuries, the plaintiff Raymond Canfield,\nthe services of his s id wife and in the future will be deprived of the\nservices of his said wife and has in the past and will in the future be\ndeprived of the comfort and aid of her society and has been and in the\nfuture will be compelled to lay out and expend large sums of money for\ndoctor bills and authorized in or endeavor to treat and cure his gold wife of\nher injuries.\nPlaintiff, Raymond Cenfield, demands Twenty-five Thousand\n($25000.00) Dollars damages on the third count.\n(Signed) Potter & Berry\nAttorneys of plaintiffs\nNEW JERSEY SUPREME COURT\nESSEX COUNTY.\nMAE CUBBERLEY CANFIELD AND\nRAYMOND CANFIELD,\nPlaintiffs,\n-VS-\nUNITED STATES RADIUM CORPORATION,\na corporation of the State of\nDelaware,\nDefendant,\nDue and legal service of a copy\nof the within Summons and Complaint\nis hereby acknowledged this\nday of October, 1928.\nAgent of the United States\nRadium Corporation\nLaw Offices\nPOTTER AND BERRY\n60 Park Place\nNewark, N.J."
}