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Extracted text
OCR Page 1 of 7IN CHANORAY OF NEW JERSEY
Between
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KATHERINE SCHAUB,
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Complainant,
:
and
:
On Bill, to.
UNITED STATES RADICUM
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PORATION, a corporation of
the State of Delaware,
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Defendant.
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:
The answer of the defendant, United states
Radium Corporation, a corporation or the State of Delaware,
duly authorized to transact business in the State of New Jeg
sey, with its principal office in the latter State in the
City of Jersoy dity, County of Budson and State of New Jersey,
saye that:
1. Answering Paragraph 1 of the complaint here-
in, while it admits that the complainant was employed by it
during e certain period of time, it denies that the complainent
was employed by the dofendant from on or sbout the first day
of Februery, 1917, to on or about the first day of July, 1920,
and from on or about the 27th day of Now embez, 1920, to on or
about the seventh day of June, 1922; it admi ta thot complain-
ant's employment consisted in mixing a powder whion defendent
corporation supplied so complainant, with glue and water, with
which complainent gas likevise supplied by the defendant, into
a paste of the proper consistency, which paste complainant the
applied with a anall genel hair bruah to numeral a on the dials
or watches; it admits that saia operation required some akill
in the use of the brush with which it was necessary to mark
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