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{
    "localId": "75721699",
    "label": "Deposition, July , 1927",
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    "id": "75721699",
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    "contentType": "document",
    "title": "Deposition, July , 1927",
    "citationUrl": "https://catalog.archives.gov/id/75721699",
    "collections": [
        "Safety Light Collection",
        "Records Related to Radium Dial Painters"
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{
    "seq": 6,
    "pageIndex": 0,
    "type": "document",
    "url": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001028.pdf",
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    "ocrText": "NEW JERSEY SUPREME COURT\nESSEX COUNTY.\nALBINA LARICE and JAMES A LARICE\nPlaintiffs,\nvs\nUNITED STATES RADIUM CORPORATION, a\ncorporation of the State of Delaware,\nDefendant.\nAction at Law\nCOMPLAINT\nDue and legal service of a copy of\nthe within Summons and complaint\nis hereby acknowledged this\nday\nof July,1927.\nAgent of the United States Radium\nCorporation.\nNEW JERSEY SUPREME COURT\nESSEX COUNTY.\n:\nALBINA LARICE and JAMES A.\nLARICE,\n:\nPlaintiffs,\n:\n:\nAction-At-Law\nvs\n:\nCOMPLAINT.\nUNITED STATES RADIUM CORP-\nORATION, a corporation of\n:\nthe State of Delaware,\n:\nDefendant.\nPlaintiffs, Albina Larice and James A. Larice, residing in the\nCity of Orange, County of Essex and State of New Jersey, complaining\nsays that:\nFIRST COUNT.\n1. From on or about August 1,1917 to on or about June 1,1919, the\ndefendant, United States Radium Corporation was a corporation engaged\nin the extraction and manufacture of radioactive substances and the\nmanufacture of products of the said radioactive substances for commercial\npurposes, having its principal place of business at the corner of Alden\nand High Streets in the City of Orange, County of Essex and State of\nNew Jersey.\n2. Said radioactive substances which were radium, mesothorium and\nthorium-x are highly an gerous substances and injurious to the human\nbody when brought into close proximity therewith as those in charge of\nthe defendant's operations well knew.\n3. The defendant well knowing the dangerous nature of the said radio-\nactive substances failed to keep the same in control but was negligent in\nallowing the said dangerous substances to escape and come within close\nproximity with the person of the plaintiff, Albina Larice, where the said\nplaintiff was lawfully entitled to be and the said defendant was negligent\nin that it carelessly and negligently placed said substances so that the\nplaintiff, Albina Larice was exposed to the penetrative rays of the said\nsubstances, inhaled the dust of the said radioactive substances and the\nemanations thereof and ingested the same to the said plaintiff's great\ndamage.\n4. Plaintiff, Albina Larice was not informed or warned and had no\nknowledge of the nature of the said dangerous radioactive substances into\nclose proximity with which she was by the defendant's negligence brought.\n5. Plaintiff, Albina Larice was exposed to said radioactive substanc-\nes for the greater part of the day time during a period of time from on or\nabout the last day of August, 1917 to on or about the first day of June, 1919.\n6. By reason of the defendent's negligence as hereinbefore set forth\nin paragraph 3 of this count, the body of the plaintiff, Albina Larice\nbecame impregnated with said radioactive substances.\n7. Said radioactive substances so introduced into the system of the\nplaintiff, Albina Larice still continue to bombard said plaintiff's body\ninternally and continually attack and break down the said plaintiff's\ntissues and body substance causing the said plaintiff, Albina Larice there-\nby great pain and suffering both mental and physical.\n8. The effect of the introduction of the said radioactive substances\ninto the human body is such as not to become immediately apparent and\nplaintiff, Albina Larice, did not feel said effects or know of the beginn-\ning of the continuing injury done to her until several years following\nher last exposure to said dangerous radioactive substances and plaintiff,\nAlbina Larice was not apprised of the nature of her bodily ailments or\ninformed or knew that her suffering was due to the negligence of the\ndefendant until October,1925.\n9. By reason of the premises the plaintiff, Albina Larice was and\nis sick, sore, lame, disabled and crippled and will forever so remain\nuntil her death which is imminent because of defendant's negligence, her\npain and suffering both mental and physical continually increasing from\nthe time of the first onset of her illness unto the present time, and\nduring all this period the plaintiff, Albina Larice underwent and suffer-\ned and will in the future undergo and suffer great pain both mental and\nphysical and the plaihtiff, Albina Larice has been, is and in the future\nwill be hindered and prevented from transacting her necessary and lawful\naffairs and has been, is and will be deprived of divers large gains and\nmoney spent in endeavoring to be cured of said disability and incapacity\nreceived as aforesaid.\nPlaintiff, Albina Larice demands One Hundred and Twenty-Five Thousand\n($125,000) Dollars damages on the first count.\nSECOND COUNT.\n1. Paragraphs 1 and 2 of the first count are hereby repeated as\nparagraph 1 of the second count.\n2. During a period from on or about the first day of August,1917\nuntil on or about the first day of June, 1919, plaintiff, Albina Larice\nwas employed as a servant of the defendant corporation to work in the\ndefendant's factory in Orange, aforesaid.\n3. Defendant failed to provide the plaintiff, Albina Larice with a\nsafe place to work but ordered and instructed the plaintiff, Albina Larice\nto handle and to be constantly in close proximity with quantities of\ndangerous radioactive substances.\n4. Plaintiff, Albina Larice did not know of the dangerous nature of\nthe said radioactive substances or their harmful effects upon the human body.\n5. Defendant gave no warning to the plaintiff, Albina Larice of the\ndangerous nature of the said radioactive substances into close proximity\nwith which plaintiff, Albina Larice was brought but constantly ordered and\ndirected the plaintiff, Albina Larice to be brought into close proximity\nwith said dangerous radioactive substances with the result that the plain-\ntiff, Albina Larice was exposed to the penetrative rays of the said radio-\nactive substances and the emanations thereof and the plaintiff, Albina\nLarice further ingested said radioactive substances to the said plaintiff's\ngreat damage.\n6. Plaintiff, Albina Larice repeats paragraphs 6,7 and 8 of the first\ncount and paragraph 6 of the second count.\n7. As a result of the said introduction of the said dangerojs radio-\nactive substances into the body of the plaintiff, Albina Larice and the\ndefendant's neglect to provide a safe place for the said plaintiff to work\nand of defendant's neglect to warn the said plaintiff of the dangerous\nnature of the said radioactive substances plaintiff, Albina Larice has\nbecome sick, sore lame and disabled and has suffered, still suffers and\nwill continue to suffer great pain both mental and physical and has been\nprevented and will be prefented from pursuing and transacting her lawful\nbusiness and plaintiff, Albina Larice has likewise been compelled and\nwill be in the future compelled to outlay and expend great sums of money\nin an endeavor to 'be cured of said disability and incapacity received as\naforesaid.\nPlaintiff, Albina Larice demands One Hundred and Twenty-five Thousand\n($125,000) Dollars damages on the second count.\nTHIRD COUNT.\n1. The plaintiff, James A. Larice repeates the allegations of para-\ngraphs 1 to 9 inclusive of the first count and paragraphs 1 to 7 inclusive\nof the second count as paragraph 1 of the third count.\n2. The plaintiff, Albina Larice mentioned in the first and second\ncounts of this complaint is the wife of the plaintiff James A. Larice.\n3. By reason of the defendant's negligence as set out in the first\nand second counts of this complaint the said Albina Larice sustained the\ninjuries as set out in the first and second counts and in consequence of\nsaid injuries the plaintiff, James A. Larice lost the services of his daid\nwife and in the future will be deprived of the services of his said wife\nand has in the past and will in the future be deprived of the comfort and\naid of her society and has been and in the future will be compelled to lay\nout and expend large sugs of money for doctor bills and medicines in an\nendeavor to treat and cure his said wife of her injuries.\nPlaintiff, James A. Larice demands Twenty-five Thousand ($25,000)\nDollars damages on the third count.\n(signed)\nPotter & Berry\nAttorneys of Plaintiffs"
}