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NEE JERSES SUPREZE COURT
ESSEX COUNTT.
MAE CUBBERLEY CANFIELD, and
#
RAYWOND CANFIELD,
Plaintiffs,
:
-VS-
de
UNITED STATES RADIUM CORPORA-
;
TION, a corporation of the
State of Dolaware,
:
letion-At-law
Defendant.
#
COMPLAINT.
Plaintiffs, Mae Cubberley Canfield and Rayzond Canfield,
residing in the City of Newark, County of Essex and State of New Jersey,
say that:
1. From September 1,1916 to March 1,1918, the defendant
United States Radium Corporation was e corporation engaged in the
extraction and manufacture of redioactive substances and the menufacture
of products of and rediosetive substances for connercial purposes,
having its principal place of business, first, on Third Street, in the City
of Newark, County of Essex and State of Nou Jersey, and subsequently at
the corner of Alden and High Streets, in the City of Orange, County of
Essex and State of New Jersey.
2. Said redioactive aubstances, which were radium,
nesothorium and thorium-x, are highly deagerous substences and injurious
to the human body when brought into close proximity therewith as those in
charge of the defendent's operations well knew.
3. The defendent, well knowing the dangerous nature of the
said redionetive substences, failed to keep the ance in control but was
negligent in allowing the soid dangerous substances to escape and come
within close proximity with the person of the plaintiff, Kae Cubberly
Canfield, where the said plaintiff was laufully entitled to be, and the
said defendant was negligent in that it carclessly and negligently placed
said substances so that the plaintiff, liae Cubberly Canfield, was exposed
to the penetrative raya of the soid substances, inhaled the dust of the
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"ocrText": "NEE JERSES SUPREZE COURT\nESSEX COUNTT.\nMAE CUBBERLEY CANFIELD, and\n#\nRAYWOND CANFIELD,\nPlaintiffs,\n:\n-VS-\nde\nUNITED STATES RADIUM CORPORA-\n;\nTION, a corporation of the\nState of Dolaware,\n:\nletion-At-law\nDefendant.\n#\nCOMPLAINT.\nPlaintiffs, Mae Cubberley Canfield and Rayzond Canfield,\nresiding in the City of Newark, County of Essex and State of New Jersey,\nsay that:\n1. From September 1,1916 to March 1,1918, the defendant\nUnited States Radium Corporation was e corporation engaged in the\nextraction and manufacture of redioactive substances and the menufacture\nof products of and rediosetive substances for connercial purposes,\nhaving its principal place of business, first, on Third Street, in the City\nof Newark, County of Essex and State of Nou Jersey, and subsequently at\nthe corner of Alden and High Streets, in the City of Orange, County of\nEssex and State of New Jersey.\n2. Said redioactive aubstances, which were radium,\nnesothorium and thorium-x, are highly deagerous substences and injurious\nto the human body when brought into close proximity therewith as those in\ncharge of the defendent's operations well knew.\n3. The defendent, well knowing the dangerous nature of the\nsaid redionetive substences, failed to keep the ance in control but was\nnegligent in allowing the soid dangerous substances to escape and come\nwithin close proximity with the person of the plaintiff, Kae Cubberly\nCanfield, where the said plaintiff was laufully entitled to be, and the\nsaid defendant was negligent in that it carclessly and negligently placed\nsaid substances so that the plaintiff, liae Cubberly Canfield, was exposed\nto the penetrative raya of the soid substances, inhaled the dust of the"
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