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solicitors of the above complainants, and Messrs. Collins & Corbin
and Edwards & Smith, solicitors of the defendant, United States
Radium Corporation.
1. That the above complainants were employed by the
defendant, United States Radium Corporation, to paint the numerals
on the dials of watches with a substance which the defendant,
United States Radium Corporation, furnished to the complainants,
2. That said substance, furnished by the defendant to
the complainants to paint on the numerals of the dials of watches,
contained radium and mesothorium in varying quantities,
3. That said radium and mesothorium contained in said
substance furnished by the defendant in varying amounts has been
known, since the year 1900, to students and scholars in that
branch of physics, chemistry and medicine that deals with radio-
active substances, to be destructive to bodily tissues when brought
into close proximity therewith, and upon this knowledge was based
the therapeutic use of said radioactive substances.
4. That defendant never informed the complainants of
the ingredients of the substance which complainants were in-
structed to use.
5. That the defendant, United States Radium Corpora-
tion, gave no warning to the complainants of any danger in
handling the substance which defendant furnished to the com-
plainants to paint on the numerals of the dials of watches.
6. That at the time of their employment complainants
were all, with one exception, minors under the age of 21 years.
7. That defendant corporation instructed complainants,
through their officers and agents, to use two kinds of thinners,
or binders in mixing a powder into a paste to be applied by the
complainants to the numerals on the dials of watches, one of
which was an oil and the other was water, so that complainants
used two kinds of paste on the numerals of the dials of watehes,
1--a water soluble paste and 2-- an oil soluble paste.
2
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Context sent to Scholar
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"ocrText": "solicitors of the above complainants, and Messrs. Collins & Corbin\nand Edwards & Smith, solicitors of the defendant, United States\nRadium Corporation.\n1. That the above complainants were employed by the\ndefendant, United States Radium Corporation, to paint the numerals\non the dials of watches with a substance which the defendant,\nUnited States Radium Corporation, furnished to the complainants,\n2. That said substance, furnished by the defendant to\nthe complainants to paint on the numerals of the dials of watches,\ncontained radium and mesothorium in varying quantities,\n3. That said radium and mesothorium contained in said\nsubstance furnished by the defendant in varying amounts has been\nknown, since the year 1900, to students and scholars in that\nbranch of physics, chemistry and medicine that deals with radio-\nactive substances, to be destructive to bodily tissues when brought\ninto close proximity therewith, and upon this knowledge was based\nthe therapeutic use of said radioactive substances.\n4. That defendant never informed the complainants of\nthe ingredients of the substance which complainants were in-\nstructed to use.\n5. That the defendant, United States Radium Corpora-\ntion, gave no warning to the complainants of any danger in\nhandling the substance which defendant furnished to the com-\nplainants to paint on the numerals of the dials of watches.\n6. That at the time of their employment complainants\nwere all, with one exception, minors under the age of 21 years.\n7. That defendant corporation instructed complainants,\nthrough their officers and agents, to use two kinds of thinners,\nor binders in mixing a powder into a paste to be applied by the\ncomplainants to the numerals on the dials of watches, one of\nwhich was an oil and the other was water, so that complainants\nused two kinds of paste on the numerals of the dials of watehes,\n1--a water soluble paste and 2-- an oil soluble paste.\n2"
}