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knew that the application which she made to the dials of 2- Donnkhan watches was for the purpose of rendering the numerals on sai d no knowled yrs as dials luminous in the dark, and from the name of the Corpora- to - tion drew the natural inference that an ingredient of the substance she applied was radium, whion is comonly known to have the characteristic of luminosity in the dark, complainant nevertheless possessed no skill or knowledge of physics or chemistry and con sequently was uninformed as to the dangerous nature of said radium or other radiosctive substances whieb were contained in said mixture applied to the watches. 3. The asid radionetive substapees which were used by the said defendent Corporation, and supplied by it to the complain ant, to be applied by thecomplainent in the manner hereinbefore D sot forth, were radium, mesothorium and thorium-xd Said radio active substances are highly dangerous and destructive to bodily tissues when brought in close proximity therewith, aa those in charge of the defendent's operations well knew. 4. Although defendent, United States Radium Corporation, well imew that the said radium, nesothorium, and thorium-x were exceedingly haraful to bodily tissues whe brought in olose proximity therewith, it gave no warning to the conplain- ant of the same but on the contrary, constantly instructed and required complainant to be in olose proximity with suid radio- active substances with the result that complainent was exposed to the raya of the said radioactive substmoes and the emans- tiona thoreof, and ingested anid radioactive substances to the complainant's great danege, as a result of which omplainant, throughout the period set forth in paragraph 1 of this bill of complaint, constantly absorbed quantities of radioactive sub- stances until her body becane impregnated throughout with said radionctive substances, this condition being brought about by the cumulative effect of the repeated amall quantities ingest- ed and breathed in plus the effect of the emanstions from the

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0
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photo
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Core
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Type
document
DTO data
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Document identity
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Document source metadata
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Document source extras
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Page context
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    "seq": 2,
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    "ocrText": "knew that the application which she made to the dials of\n2- Donnkhan\nwatches was for the purpose of rendering the numerals on sai d\nno knowled yrs as\ndials luminous in the dark, and from the name of the Corpora-\nto -\ntion drew the natural inference that an ingredient of the\nsubstance she applied was radium, whion is comonly known to\nhave the characteristic of luminosity in the dark, complainant\nnevertheless possessed no skill or knowledge of physics or\nchemistry and con sequently was uninformed as to the dangerous\nnature of said radium or other radiosctive substances whieb\nwere contained in said mixture applied to the watches.\n3.\nThe\nasid\nradionetive\nsubstapees\nwhich\nwere\nused\nby\nthe\nsaid defendent Corporation, and supplied by it to the complain\nant, to be applied by thecomplainent in the manner hereinbefore\nD\nsot forth, were radium, mesothorium and thorium-xd Said radio\nactive substances are highly dangerous and destructive to\nbodily tissues when brought in close proximity therewith, aa\nthose in charge of the defendent's operations well knew.\n4. Although defendent, United States Radium Corporation,\nwell imew that the said radium, nesothorium, and thorium-x\nwere exceedingly haraful to bodily tissues whe brought in\nolose proximity therewith, it gave no warning to the conplain-\nant of the same but on the contrary, constantly instructed and\nrequired complainant to be in olose proximity with suid radio-\nactive substances with the result that complainent was exposed\nto the raya of the said radioactive substmoes and the emans-\ntiona thoreof, and ingested anid radioactive substances to the\ncomplainant's great danege, as a result of which omplainant,\nthroughout the period set forth in paragraph 1 of this bill of\ncomplaint, constantly absorbed quantities of radioactive sub-\nstances until her body becane impregnated throughout with said\nradionctive substances, this condition being brought about by\nthe cumulative effect of the repeated amall quantities ingest-\ned and breathed in plus the effect of the emanstions from the"
}