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OCR Page 1 of 6SCHEDILI "A"
NEW JERSEY SUPREME COURT
ESSEX COUNTY
CATHERINE CONNOLLY and
)
THOMAS CONNOLLY, her husband,
)
Plaintiffs,
)
ACTION AT LAW
-VS-
)
COMPLAINT
UNITED STATES RADIOM
CORPORATION (formerly Radium
)
Luminous Material Corp.) a
corporation of the State of
)
Delaware,
)
Defendant.
)
Plaintiffs, Catherine Connolly and Thomas Connolly, her
husband, residing in the City of Newark, County of Essex and State of New
Jersey, complaining of the defendant, says that:
FIRST COUNT
1.
At the times hereinafter mentioned, the defendant was engaged
in the business, among other things, of menufacturing and distributing radium
and radium products and manufacturing and distributing radium and other
luminous materials.
2.
The plaintiff Catherine Connolly was employed by the defendant
for a period of time from 1917 to 1924 at its plants in the Cities of Newark
and Orange, New Jersey.
3.
At the time and place aforesaid, the said plaintiff was directed
by the agents and servants of the defendant to mix certain luminous materials
into paint and to apply the said paint to the surface of various cardboard and
netal materials, principally used in the manufacture of watches, clocks and
luminous signs.
4.
The materials used in making said luminous paint and the im-
plements employed in mixing and applying said paint were furnished by the
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