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OCR Page 1 of 8UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
CATHERINE CONNOLLY and
:
THOMAS CONNOLLY, her
husband,
:
Plaintiffs,
:
IN EQUITY
VS.
:
COMPLAINT
UNITED STATES RADIUM
:
CORPORATION (formerly
Radium Luminous Material
:
Corp.), a corporation of
the State of Delaware,
:
Defendant,
##
The plaintiff, Catherine Connolly, residing in the City
of Newark, County of Bssex and State of New Jersey, complaining of the
defendent above-named, says that:
FIRST COUNT
1.
The plaintiff is a resident and citizen of the Cita of Newark,
County of Essex and State of New Jersey.
2.
The defendant is a corporation of the State of Delaware.
3.
The amount in controversy herein exceeds the sum of Three
Thousand Dollars exclusive of interest and costs.
4.
At the times hereinafter mentioned, the defendent was engaged
in the business, among other things, of manufacturing and distributing radium
and radium products and mamufacturing and distributing radium and other
luminous materials.
5. The defendant maintained a plant or factory in the municipality
of Orange, New Jersey, as well as in the City of Newark, New Jersey, where it
carried on the work aforesaid and where it employed persons to render
luminous dials of time pieces by the application of radio active substances.
6.
The plaintiff herein heretofore instituted suit in this court
at law against the defendant for damages resulting from the conduct of the
defendant toward the plaintiff, Catherine Connolly, while the latter was em-
ployed by the defendant to paint the dials of time pieces as aforesaid. A
copy of the complaint is annexed hereto, made part hereof and marked
Schedule A.
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