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3. Said radioactive substances referred to in paragraphs 1 and 2
of this complaint 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 thedefendants' operations
well knew.
4. The defendants, United States Radium Corporation and The Luminite
Corporation, well kmowing the dangerous nature of the said radionctive
substances failed to keep the sane in control but were negligent in al-
lowing the said dangerous substances to escape and come within close
proximity with the plaintiff's person where the said plaintiff was law-
fully entitled to be and the said defendants were negligent in that
they carelessly and negligently placed said substances so that the
plaintiff was exposed to the penetrative rays of the said substances,
inhaled the dust of the said redioactive substances and emanations
thereof and ingested the name to the plaintiff's great damago.
5. Plaintiff was not informed or warned and had no knowledge of t he
nature of the said dangerous redioactive substances into close proximity
with which she was by the defendants negligence brought.
6. Plaintiff was exposed to said radioactive substances for the
greator part of the day time during a period of time from on or about
the first day of February, 1917 to on or about the first day of July.
1920, and from on or about the 27th day of November 1920 to June 7,1922,
at the plant of the defendant, United States Radium Corporation
hereinbeforo roferred to in paragraph 1 of this count and from on or
about the 7th day of June,1922 to on or about September 27,1923, at the
plant of the Luminite Corporation, referred to in paragraph 2 of
this count.
7. By reason of the defendants' nogligence as hereinbefore set
forth in paragraph 4 of this count, the plaintiff's body became Im-
pregnated with said radioactive substances.
8. Said radioactive substances so introduced into the plaintiffis
system still continue to bombard plaintiff's body internally and con-
tinually attack and break dom the plaintiff's tissues and body substance
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Context sent to Scholar
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"ocrText": "3. Said radioactive substances referred to in paragraphs 1 and 2\nof this complaint which were radium mesothorium and thorium-x are highly\ndangerous substances and injurious to the human body when brought into\nclose proximity therewith as those in charge of thedefendants' operations\nwell knew.\n4. The defendants, United States Radium Corporation and The Luminite\nCorporation, well kmowing the dangerous nature of the said radionctive\nsubstances failed to keep the sane in control but were negligent in al-\nlowing the said dangerous substances to escape and come within close\nproximity with the plaintiff's person where the said plaintiff was law-\nfully entitled to be and the said defendants were negligent in that\nthey carelessly and negligently placed said substances so that the\nplaintiff was exposed to the penetrative rays of the said substances,\ninhaled the dust of the said redioactive substances and emanations\nthereof and ingested the name to the plaintiff's great damago.\n5. Plaintiff was not informed or warned and had no knowledge of t he\nnature of the said dangerous redioactive substances into close proximity\nwith which she was by the defendants negligence brought.\n6. Plaintiff was exposed to said radioactive substances for the\ngreator part of the day time during a period of time from on or about\nthe first day of February, 1917 to on or about the first day of July.\n1920, and from on or about the 27th day of November 1920 to June 7,1922,\nat the plant of the defendant, United States Radium Corporation\nhereinbeforo roferred to in paragraph 1 of this count and from on or\nabout the 7th day of June,1922 to on or about September 27,1923, at the\nplant of the Luminite Corporation, referred to in paragraph 2 of\nthis count.\n7. By reason of the defendants' nogligence as hereinbefore set\nforth in paragraph 4 of this count, the plaintiff's body became Im-\npregnated with said radioactive substances.\n8. Said radioactive substances so introduced into the plaintiffis\nsystem still continue to bombard plaintiff's body internally and con-\ntinually attack and break dom the plaintiff's tissues and body substance"
}