Ask the Scholar
Page 3 of 5
I can add historical knowledge about this page.
Page image
OCR
lawful arrairs and has been, is and will be deprived or divers targe
gains and monoy spent in endeavoring to be cured of soid disability and
incapacity received as aforesnid.
Plaintiff, Quinta McDonald demands One Hundred and Teanty-Five Thou-
sand ($125,000) Dollars damages on the first count.
SECOND COUNT.
1. Paragraphs 1 and 2 of the first count are hereby repented as
paragraph 1 of the second count.
2. During a period from on or about the first day of March, 1917 un-
til on or about the first day of February, 1919, plaintifi, Quinta Nc-
Donald was employed as a servant of the defendant corporation to work in
the defendant's factory in Orange, aforesaid.
3. Defendant feiled to provide the plaintiff, Quinta licDonald with
a safe place to work but ordered and instructed the plaintiff, Quinta
McDonald to handle and to be constantly in close proximity with quanti-
ties of dengerous radioactive substances.
4. Plaintiff, Quinta McDonald did not know of the dengerous nature
of the said radioactive substances or their harmful effects upon the
human body.
5. Defendant gave no varning to the plaintiff, Quinta licDonald of
the dangerous nature of said radioactive substaces into close proximity
with thich plaintiff, Quinta McDonald was brought but constantly ordered
and directed the plaintifi, Quinta 1/cDonald to be brought into close
proximity with said dangerous radioactive substances with t he result
that the plaintiff, Quinta McDonald was exposed to the penetrative rays
of the said radioactive substances and the emanations thereof and the
plaintiff, Quinta McDonald further ingested said radioactive substances
to the said plintiff's great damage.
6. Plaintiff, Quinta McDonald repeats paragraphs 6,7 and 8 of the
first count and paragraph 6 of the second count.
7. As a result of the said introduction of the said dangerous radio-
active substances into the body of the plaintiff, Quints and
the defendant's noglect to provide a safe place for the ssid plaintiff
Page data
- Page
- 3
- Source index
- 0
- Type
- photo
- Media ID
- 750b9a9c76f474cc
- Size
- unknown
Document data
- ID
- 75730581
- Core
- doc
- Type
- document
DTO data
{
"id": "75730581",
"sourceUrl": "https://catalog.archives.gov/id/75730581",
"contentType": "document",
"title": "Check, no date",
"citationUrl": "https://catalog.archives.gov/id/75730581",
"collections": [
"Safety Light Collection",
"Records Related to Radium Dial Painters"
],
"iiifBase": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0003655_Page_1.jpg",
"thumbnailUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0003655_Page_1.jpg",
"largeImageUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0003655_Page_1.jpg",
"imageCount": 5,
"hasImages": true,
"source": "import",
"hasTranscription": false
}
Context sent to Scholar
Document identity
{
"localId": "75730581",
"label": "Check, no date",
"core": "doc",
"dtoType": "document",
"citationUrl": "https://catalog.archives.gov/id/75730581"
}
Document source metadata
{
"id": "75730581",
"sourceUrl": "https://catalog.archives.gov/id/75730581",
"contentType": "document",
"title": "Check, no date",
"citationUrl": "https://catalog.archives.gov/id/75730581",
"collections": [
"Safety Light Collection",
"Records Related to Radium Dial Painters"
],
"iiifBase": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0003655_Page_1.jpg",
"thumbnailUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0003655_Page_1.jpg",
"largeImageUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0003655_Page_1.jpg",
"imageCount": 5,
"hasImages": true,
"source": "import",
"hasTranscription": false
}
Document source extras
{
"url": "https://catalog.archives.gov/id/75730581",
"naId": 75730581,
"levelOfDescription": "fileUnit",
"recordType": "description",
"ocrSource": "nara-archive"
}
Page context
{
"seq": 3,
"pageIndex": 0,
"type": "photo",
"url": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0003655_Page_3.jpg",
"mediaId": "750b9a9c76f474cc",
"ocrText": "lawful arrairs and has been, is and will be deprived or divers targe\ngains and monoy spent in endeavoring to be cured of soid disability and\nincapacity received as aforesnid.\nPlaintiff, Quinta McDonald demands One Hundred and Teanty-Five Thou-\nsand ($125,000) Dollars damages on the first count.\nSECOND COUNT.\n1. Paragraphs 1 and 2 of the first count are hereby repented as\nparagraph 1 of the second count.\n2. During a period from on or about the first day of March, 1917 un-\ntil on or about the first day of February, 1919, plaintifi, Quinta Nc-\nDonald was employed as a servant of the defendant corporation to work in\nthe defendant's factory in Orange, aforesaid.\n3. Defendant feiled to provide the plaintiff, Quinta licDonald with\na safe place to work but ordered and instructed the plaintiff, Quinta\nMcDonald to handle and to be constantly in close proximity with quanti-\nties of dengerous radioactive substances.\n4. Plaintiff, Quinta McDonald did not know of the dengerous nature\nof the said radioactive substances or their harmful effects upon the\nhuman body.\n5. Defendant gave no varning to the plaintiff, Quinta licDonald of\nthe dangerous nature of said radioactive substaces into close proximity\nwith thich plaintiff, Quinta McDonald was brought but constantly ordered\nand directed the plaintifi, Quinta 1/cDonald to be brought into close\nproximity with said dangerous radioactive substances with t he result\nthat the plaintiff, Quinta McDonald was exposed to the penetrative rays\nof the said radioactive substances and the emanations thereof and the\nplaintiff, Quinta McDonald further ingested said radioactive substances\nto the said plintiff's great damage.\n6. Plaintiff, Quinta McDonald repeats paragraphs 6,7 and 8 of the\nfirst count and paragraph 6 of the second count.\n7. As a result of the said introduction of the said dangerous radio-\nactive substances into the body of the plaintiff, Quints and\nthe defendant's noglect to provide a safe place for the ssid plaintiff"
}