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NEW JERSEY SUPREME COURT ESSEX COUNTY. MAE CUBBERLY CANFIELD et al. Plaintiffs, ACTION AT LAW. EXAMINATION BEFORE TRIAL. VS. U. S.RADIUM CORPORATION, Defendant. Before HARRY SCHIRMER. SUPREME COURT EXAMINER. INDEX Direct Cross Re-Direct Re-Cross Mae Cubberly Canfield 2 Raymond Canfield 38 Mae C. Canfield, rec. 46 HARRY SCHIRMER Law Stenographer Supreme Court Examiner I Exchange Place Jersey City, N.J. fees OF EXAMINER. One session fee $6.00 Administering two oaths .50 Depositions, 116 fols. 34.80 Certificate .50 $41.80 HARRY SCHIRMER, Supreme Court Examiner. 1 NEW JERSEY SUPREME COURT ESSEX COUNTY. MAE CUBBERLY CANFIELD : and RAYMOND CANFIELD, : Plaintiffs, : ACTION AT LAW. VS. : EXAMINATION BEFORE TRIAL. U. S. RADIUM CORPORATION, a corporation of the State of : Delaware, Defendant. : Examination of plaintiffs in the above entitled cause before trial, taken before me, Harry Schirmer, a Supreme Court Examiner of the State of New Jersey, at the office of Messrs. Potter de Berry, 60 Park Place, Newark, New Jersey, this seventeenth day of January, 1929, at four o'clock in the afternoon, under Section 144 of the Practice Act of 1903, as amended, pursuant to order. Appearances: Messrs. Potter de Berry, Attorneys for Plaintiffs; Messrs. Collins de Corbin, (Mr. Markley), Messrs. Edwards de Smith (Mr. Smith), Attorneys for Defendant. It is stipulated that the examination be taken stenographically and the signatures of the witnesses waived. 2 STATE OF NEW JERSEY : : SS. COUNTY OF ESSEX : MAE CUBBERLY CANFIELD, being first duly sworn according to law, on her oath deposes and says : EXAMINATION BY MR. SMITH: Q Mrs. Canfield, what is your full name ? A Mae Cubberly Canfield. Q. Where do you live ? A. Now ? Q Now. A. At 370 New Street, Newark. Q Are you married ? A. Yes. Q What is your husband's name ? A. Raymond Canfield. Q Where were you married ? A. In East Orange. Q And when ? A. December 23d, 1917. Q In a church ? A. No; in the parsonage. Q Who was the minister ? A. Reverend Giles. a And how old are you ? A. 37. Q Have you any children ? A. Yes; three. Q Three ? A. Three children. Q, What are their names; give me the names and ages of each ? A Pershing, ten years; Raymond, seven years; and Patricia two and a half years. Q They are all living ? A. Yes. Q They live with you, I presume, don't they ? A. Yes. Q All in good health ? A. Yes. 3 Q You worked for the U. S. Radium Company ? A. 1 did. Q When did you first go into their employ ? A In 1916. Q Where was its place of business then ? A On Third Street. Q Newark ? A. Newark. Q What position did you have then ? A. Dial painter. Q Dial painter ? A. Dial painter, yes. Q Who was your immediate superior ? A Miss Rooney was our floorlady, and Mr. Savoye was really the boss of that plant. Q What date did you go into their service, do you know ? A 1916. Q Do you know what month ? A I think it was in September. Q How long did you remain dial painting for them ? A 1 was there until 1 left, 1918. Q In left when ? A. In 1918. Q Were you continuously dial painting ? A Yes;I was dial painting. Q All the time ? A Well, I was instructor; when they moved up to the Orange plant, why, I instructed girls; they had hired some new girls when they moved up there, so Mr. Saro ye sent me up there to 4 hire girls and instruct them in the painting for about two weeks, I guess. Q You hired them and instructed them? A. Yes. Q While you were dial painting, vil 11 you just tell me what you did; just how did you do it ? A Well, we put the brush in that crucible with the radium in, painting numerals on the watches. Q What size crucible was there in front of you ? A Well, I should say about like that (indicating), a small, little crucible. Q What is the size of that; about the size of a quarter ? A I guess so; they were very small; not a large amount of radium fot them at a time. Q How deep were they, would you say ? A Well, 1 guess sbout that (indicating). Q About an inch ? A. About an inch, I guess. Q. Did you put the stuff in it yourself ? A Oh, yes; it was given to us in little bottles, they we put it in the crucible, put so many drops of color, then so many drops of water, then mixed the stuff; when it was nice and smooth, then we paint with it. Q Then you mixed it yourself ? A. Yes. Q How did you mix it; with the brush ? A No; with a little glass mixer. 5 Q That is just like a glass stylus that you turn it around with ? A. Yes. Q This brush that you had, what was it, a camel hair brush? A A camel hair brush. Q How large was it ? A Well, 1 guess they were about like that (indicating). Q About eight inches long ? A Well, something like that, I guess. Q What was the handle made of; wood ? A Yes; wood. Q Then it had the camel hair at the end ? A Yes, at the end. Q Were they pointy brushes ? A No; they were just ordinary brushes, you know, that you use when you paint things in books, you know, children's books Q But the end of the brush was pointy; it wasn't flat across? A Well, it wasn't a real pointy brush. Q Having mixed the preparation, you say you put the brush in and then painted the dials ? A And painted the dials, yes. Q Was it the dial you painted, or just the numerals on the dials ? A The numerals on the dial. Q When did they move from Third Streetate Orange ? 6 A In June, of 1917. Q In June, 1917 ? A. Yes. Q You went with them ? A. Yes. Q How long did you work for them at Orange ? A From that time until 1918. Q From that time until 1918 ? A. Yes. Q In what month did you quit, in 1918 ? A I think it was in March. Q In March, 1918 ? A Yes; either the latter part of February or the first of March. Q When you say you instructed the girls up there, just tell me how you instructed them ? A Well, of course, they had what they call brass dials. Q Yes. A. Which was on a long strip, about eight on a strip little watches; then, of course, we used some kind of imitation radium, it wasn't radium, you know, it wasn't the real stuff, because you couldn't do that, you mix it just the same as radium. Q Yes. A. Then they had a glass of water with a little crucible, and the glass of water was to wash your brush off, because the radium used to harden, you know, on the brush, and then you couldn't use it, then you dip it in the water and shake it off, then put the brush in your mouth and 7 point it, then dip it in the radium and then paint the dial. Q You put the brush in your mouth ? A. Oh, yes. Q And you instructed the girls to put the brush in their mouth ? A 1 was instructed that way; 1 didn't know any other way. of Did you say you were instructed ? A. Why, surely. Q Who instructed you that way ? A Well, the girl's name, 1 think, was Ruth Gegeheim. Q She was your instructress ? A. Yes, sir; she instructed me. Q Where was she employed; at Third Street ? A At Third Street. Q That was when; in 1916 ? A That was in 1916. Q In 1916 ? A. Yes. or What instructions did she give you relative to putting the brush in your mouth ? A Well, we couldn't, you know, paint with the brush, it would spread as we were painting; it would spread, you know. Q Yes. A And unless you put the edge in your mouth you couldn't get a decided point, and the point had to be a decided point to paint the numerals, because if you didn't have a point it would go on the outside then. 8 Q Then you did that in order to point the brush ? A Yes. Q You couldn't point the brushes in this glass of water that you said was there ? A. No. Q Why ? A Well, you couldn't dip it in, there would be water on the brush. Q Then, because water was on the rush, is the reason you could not point it, is that it ? A No; you would shake the water out, but it wouldn't be pointy; you had to have it 80 it would stick together. Q In other words, you would have to have the brush 80 that the brush would stick together into a fine point. A Yes; otherwise if you put it into the radium like that it would be a little full, you know, it would be too full and it would paint a big spot on the dial instead of the number. Q, It was Miss Ruth Gegenheim who instructed you? A As I remember; Miss Rooney was our forelady. Q Was it Miss Rooney, or Miss Gegenheim ? A Miss Gegenheim; because Miss Rooney was the forelady; she didn't know how to paint; if any new girl came she would say, "You go up and teach the new girl how to paint the dials". Q As I understand you, you left there in 1918. 9 A 1918; yes. Q Were you married before you went there, or after you went there ? A No, after I went there; I was married in December, 1917; the 23d of December. Q How much did you earn ? A What is that ? Q How much did you eark a week ? A We were on piece work. Q You mean that you were paid by the piece ? A Paid by the watch. Q By the watch ? A Yes; I think it was one cent and a half for a Yankee and two cents for the Midget. Q Of course the more watches you painted, the more you earned ? A The more money you earned; yes, sir. Q Can you give me an idea about what that was ? A What do you mean ? Q About what you earned a week. A Well, 1 seen the time that I made $30. when we worked overtime; about $25. I averages, I guess, twenty or twenty- five dollars, on an average; of course the other is when we worked overtime. 10 Q Then I understand you left there in 1918. A. Yes. Q And haven't been back to work for them since. A No. Q When did you first notice any pains about yourself ? A In November, 1926. Q November, 1926 ? A. Yes. Q That is the first you had ? A Yes; that is the first I had. Q Where were they ? A Well, they were in my joints; I thought 1 had Theumatism. a Your joints ? A Yes; my jaw joints. Q You thought you had rheumatism. A. Yes. Q Did you go to a doctor ? A Well,no, 1 didn't go to a doctor; it wasn't so bad, you know, as that. Q You just took home remedies/ A. Yes. Q As I understand you, what you mean is that the first pains you had were in November, 1926. A. Yes. Q You hadn't had any prior to that time ? A No; I was in perfect health. Q You were in perfect health ? A. Yes, always. Q All the way up to 1926. A. Yes, sir. 11 Q The first pains were in November, and those were pains in the joints, you say ? A Yes, in some of my joints, and in my back. Q What kind of pains were they ? A Well, kind of sharp pains, or rheumatic pains, as we called them. Q Were they sharp, or just dull ? A Well, sharp at some times, you know, kind of shooting pains. Q When did you go to see the doctor first ? A Well, I didn't go to the doctor until, it was in June, of 1928. Q You hadn't gone to a doctor until June, 1928 ? A Yes. Q All that time you had been having those pains, you say ? A Well, off and on; not bad. a Where did the pains first appear in the joints ? A Well, my jawbone seemed to hurt. Q Which one ? A All around, on both sides. a All around; that is the lower jaw ? A The lower jaw. Q That seemed to pain all the time, you say ? A No, not at first. 12 Q You mean all the way around the jaw ? A Not at first, it didn't pain all the time until this February. Q Where was it first starting to pain ? A When was it ? Q, On the left side ? A No; on the right side. Q On the right side ? A. Yes. a Is that at the joint of the jawbone ? A Yes, right in here (indicating). MR. MARKLEY: She is indicating a place a little bit below the joint. Q You mean at the joint, or in between the joint and the front part of your jaw ? A No, right in here, you see, right around here (indcating) Q That is not at the hinge ? A Well, right in here, I guess there is the hinge (indicat- ing). or Is that what you mean ? A. Yes. Q You mean from the joint around toward the front of the J an? A Yes. MR. MARKLEY: That is the right lower jaw ? THE WITNESS: That is right. Q What kind of pains were they when they first came ? 13 A Well, they seemed to be a set pain, kind of an ache. Q Just like an ache ? A Just like an ache. Q It didn't interfere with the motion of the jaw at all, did it ? A Well, up in here, where these bones come together here, why, you know, it felt funny, well, 1 don't know, as if it was, 1 can't explain that (indicating). MR. MARKLEY: The witness is referring now to the lower right jaw, right below the ear. THE WITNESS: Yes. Q That is at the right joint ? A Yes; right. Q You say it felt funny; will you just explain that as nearly as you can ? A Well, it felt like a knock or something in it. Q Like a knock in it ? A Like a knock in it; it was a peculiar feeling. Q And that lasted for how long ? A Oh, I guess about two weeks. Q About two weeks ? A. Yes. Q Did it go away ? A Yes, then it went away. 14 Q What other pains did you have in the jaw ? A In the jaw ? Q Yes. A. Only just the ache in the jawbones. Q Just the ache ? A Yes; then my gums, they were filled with pus, you know, they were swollen. Q The gums swollen ? A. Yes. Q Now, did you go to the doctor about that knock in the jaw? A Yes; 1 went to Doctor Humphreys. Q How did you come to go to Doctor Humphreys ? A Well, my sister told me to go there, because she had her little boy over there and said it was good over there, so our money was kind of scarce, I couldn't go to a regular doctor. Q You don't mean that. A. You know what I mean. Q What is your sister's name ? A. Mrs. Carsey . Q How do you spell it ? A. C-a-r-s-e-y. Q Doctor Humphreys is at the hospital, you mean, don't you ? A Orthopoedic, yes; I went to the clinic. a How often did you go to Doctor Humphreys ? A Well, when I was real bad I went every week; then when I got better I would go every two weeks, when 1 wasn't so bad. a When was the first you went to him ? A. In June. Q This was the first ? A. Yes. 15 MR. MARKLEY: 1928 ? THE WITNESS: 1928. Q What did he do for you ? A. Well, he gave me tonics. Q Anything else ? A No; he said that is about the only thing to do, to keep the blood in; get the blood up. Q, Can you give me an estimation of the number of visits you made to Doctor Humphreye ? A No, I couldn't say; I don't know; since June. Q Just approximate, that is all. A Well, I don't know; maybe twelve times. Q Twelve times ? A. Maybe more; I don't know. Q Each time he just prescribed tonics ? A Well, yes, just to change it; once in a while he would change the tonic, give me a little different one. Q is he the only doctor you went to ? A No; then 1 went to a dentist. Q Who is that ? A. Doctor Hodges. Q Where is his place ? A He is on Central Avenue and Bergen Street. Q. When did you first go to him ? A Well, 1 think it was in September; then Doctor Fields; 1 went to Doctor Fields. IR. MARKLEY: September, 1928 ? THE W TNESS: Yes. 16 Q, Doctor Fields ? A. Yes. Q He is also a dentist ? A. Yes. Q Doctor Hodges, what did he do for you ? A Well, he gave me a prescription to use in my mouth. Q That is a mouth wash, you mean ? A Yes, to hold in my mouth, you know, to relieve the pain, and also the pus, that was in the jaw, in the gums. Q Anything else that he did for you ? A No; he wouldn't touch my teeth. Q How did Doctor Fields treat you ? A Well, he wouldn't, either. Q. He didn't touch them ? A. No. Q Did he give you any wash ? A No; 1 told him what Doctor Hodges was doing, and he said that was all right. Q Then from the time that you say you first felt this pain, you haven't had any treatment of the mouth except the washes and the tonics ? A Just the tonics and the washes; yes. Q You had no teeth pulled, or no operations of any kind ? A No; the teeth fell out themselves; two teeth fell out by themselves. Q What two teeth ? A One down here on the lower jaw and one up there (indicat- 17 ing). Q One upper and one lower ? A. Yes. This one is ready to fall out (indicating). Q When did they fall out ? A This one down here fell out a year ago (indicating), in December; that would be December, 1927. Q Yes; and the upper ? A And the other fellaw out---- MR. MARKLEY: You are speaking of the lower; that is the lower fell out in December, 1927 ? THE WITNESS: In December, 1927; and this one fell out, I think it was in September or October, 1928. Q That is the upper ? A. yes. Q Have you been working; do you work outside of your own home work ? A. Just housework. Q Just housework ? A. Yes. a Taking care of your children, and so forth. A. Yes. Q You say you used to go to Doctor Humphreys once a week, and then later on once every two weeks; when was the last time you saw him? A I think it was the last the first week in December, I think, of 1928. Q When was the time before that; the last time before that 18 A It was in November some time. Q How many times in December did you go; once ? A Once in December, yes. Q And in November ? A I think I went a couple of times in November. Q And before that ? A. In August, I think, I went. Q How many times did you go in August ? A 1 think 1 went--yes, 1 went every week in August, because тухи gums were 80 bad then ; Doctor Humphrsys wasn't there; Doctor Phelps was there. Q Phelps ? A, Doctor Phelps. Q, He is in Doctor Humphreys' office ? A Yes; he and Doctor Humphreys are together. Q As I understand you, the first time you saw Doctor Humphrey was in June, 1928 ? A. Yes; June, 1928. Q Had you seen any other doctor before him ? A. No. Q You haven't had any doctor for those pains that you said you had, rheumatic pains, or anything like that ? A Well, I had a doctor in February. Q Who was he ? A. Doctor Green. Q That is 1928 ? A. In 1928. Q Doctor Green. A. Yes. Q What was he, a medical man, or dentist ? A No; he is a medical doctor. 19 Q. Where is his place ? A. On Bank Street here. Q Bank ? A. Yes. Q That is Newark ? A. Yes, Newark. Q, What did he do for you; just gave you medicine ? A Just gave me medicine, because I don't know at the time just what he was doctoring me for. Q What ? A. 1 don't know at the time, about that time; that was in February. Q February of 1928 ? A. 1928. Q You didn't know what ? A. I didn't know about the radium, you know, until I went to see Doctor Humphreys, you see. Q Did Doctor Humphreys X-ray you ? A. Yes; he X-rayed me. Q Did any other doctor X-ray you ? A. Doc tor Fields. Q. When was that ; just here lately ? A Yes; I think it was in October. Q Where did you live prior to your present address ? A Where did I live before that ? Q Yes. A. On Sixteenth Avenue. Q Sixteenth Avenue where ? A. 177. Q. Sixteenth Avenue, Orange ? A. No; Newark. Q And where before that ? A. On South Seventh Street. Q Newark, again ? A. Yes; always in Newark. A How long did you live in Sixteenth Street ? 20 A On Sixteenth Avenue ? Q Yes. A. About a year. Q And in South Seventh Street ? A. About a year. Q What was the number on South Seventh Street; can you give me that ? A. 180. Q Had you been to see Doctor Jaffe ? A. Yes. Q When did you see him ? A. 1 think it was in October # Q 1928 ? A. Yes; 1928. Q What is he, a dentist ? A. He is a dentist, yes. Q Where is his place ? A. Market and Broad. Q What did he do; just make an X-ray of you ? A No; he didn't make an X-ray. Q What did he do ? A. He sent me to Doctor Fields. Q And that is all ? A. Yes. Q He didn't examine you ? A Yes; he looked at my teeth and told me that he didn't know really what to do for me, to see Doctor Feields. Q Have you seen Doctor Blum e ? A. No; 1 haven't gone over to see him yet. BY MR. MARKLEY: Q What is your weight, Mrs. Canfield ? A Well, I guess about 142. Q, And your height ? A. I don't know how tall 1 am; five foot something; I don't know. 21 Q Do you mind just standing up a moment ? A (The witness stands as requested). MR. MARKLEY: About five foot three. Q When did you start to work for the Radium Company ? A When ? Q Yes. A. In 1916. Q What time in 1916; in September, 1 think you said ? A Sometime in September; the latter part of September, 1 think it was. Q Prior to that had you worked somewhere else ? A I worked for the L. S. Plaut Company, Newark; department store. a How long had you worked there ? A oh, I don't know; about a year, I guess. Q Prior to that had you worked somewhere ? A Well, I worked for a dressmaker; you see, I was dressmaker in L. S. Plaut & Company. Q And you were a dressmaker for somebody else prior to that? A Yes;Mrs. King her name was. Q Mrs. King ? A. Yes; she was a dressmaker. Q Where is she ? A, She lived on Twelfth Street; 1 think it was 179 South Twelfth Street. Q In Newark ? A. In Newark, yes. Q Was that your first employment ? A. Yes. 22 Q And when was that; how long ago; when did you start to work for her ? A. Oh, 1 don't know. Q Was that your first job, so to speak ? A No, I worked with different dressmakers, you know, learn- ing the trade; that is different ones, you know; first I would be with one, see, like that; 1 remember one party up in East Orange somewhere; 1 don't remember her name. Q When you left the Radium Company, you left there of your own accord ? A. Yes. Q You resigned your position ? A. I was married, yes. Q You worked there after you were married, didn't you ? A Well, I worked there for a few months after I was married; Mr. Saw ye wanted me to stay; that is the reason I stayed. Q Let me see; you were married when ? A. In 1917. Q In December, wasn't it ? A Yes; December 23d; then Mr. Savoye asked me if I would stay with him, and 1 told him yes. Q And you worked until February, 1928 ? A Yes; either February or March; 1 don't just remember. Q The last of February or the first of March ? A Yes; some where around there. Q In 1918. A. Yes. Q Then you quit. A. Yes. Q Did you work any place since then ? A. No. 23 Q Other than keeping your home. AN No. Q Did you ever do any radium painting for any other employer? A 1 didn't know what it was. Q The only place you did radium painting was--- A Yes; 1 was a dressmaker. Q. ---With the U. S. Radium Company. A. Yes. Q Were you to any other doctors or doctor than those you have named, prior to this time, for any treatment or sickness or illness ? A. No. Q You were always healthy ? A. I was always healthy. Q From 1918 right on through, up until when did you say your trouble began ? A. In 1926. q What time;in November, 1926 ? A Yes; November. Q Up until November, 1926, you were in perfect health ? A Yes. Q Did you have any doctors ? A. No. Q Did you have any severe illnesses ? A. No. Q Are you sure, now ? You just think back there and try to see if you remember any. A Nothing; I had three children, that is all; that is nothing severe. Q Did you ever have whooping cough ? A. Not that I rmmember. Q Did you have influenza ? 24 A Influenza , I think I had the influenza in 1918. Q When the spidemic was on ? A When the epádemic was going around. Q What time, do you remember when that was ? A In 1918. Q In October ? A. Right after my baby was born. Q The epidemic was in October and November. A In October. Q When was the baby born ? A. September 18th. Q You had the influenza right after that ? A Yes; when he was two weeks old. Q How long were you laid up with the influenza at that time? A Well not very long. Q A few weeks ? A. Yes; a week and a half, 1 guess. Q Did you go to the hospital ? A. No. Q You had the doctor at your home ? A. Surely. Q What doctor did you have ? A. Doctor Brown. Q Where; of Orange ? A. No; Newark. Q What is his first name, do you know ? A (No answer). Q Where is his office ? A On Roseville Avenue somewhere; he was the one I had when the baby was born. Q Don't you remember having whooping cough ? 25 A No; I don't remember having the whooping cough. Q Did you have measles ? A Not that I can remember; I may have had them; if I had them, I had them before I can remember. Q You don't remember having measles ? A No, sir; I was always healthy; of course I don't know whether I had measles or not. Q Your three children are living, aren't they ? A. Yes. Q Have you any deceased children ? A. No. Q Your mother, is she living ? A. No, she is dead. Q When did she die ? A. oh, dear, I don't know. Q How long ago, approximately ? A About twenty years ago, 1 guess; more than that, 1 guess; she died when 1 was a child. Q What was her age, about, do you know, when she died ? A 44; she died with the change of life. Q This trouble that you say you first had, with these pains-- A In November, 1926. Q Where did you first have the pains ?. A Well, in my joints and my back. Q What do you mean by your joints ? A Well, my hips, in my hip joints here, and my knees, my knee joints, and my back. Q You ha d pains in your knees and pains in your hip ? 26 A Yes. Q, And pains in your back ? A. Yes. Q Which did you have first ? A. I think in my knees first. Q How long was it after you had those that you got pains elsewhere ? A Well, I don't just recall; 1 know after that, why, my back started here, my back started, it hurt, and my hip. Q You didn't go to a doctor for this at all ? A No, I didn't go to the doctor, because everybody said it was rheumatism, so naturally it wasn't as bad. Q You didn't do anything for those pains ? A. No. Q And the first time you went to a doctor was when ; when you went to Doctor Humphreys ? A. Yes; in June. Q In June,1928 ? A. 1928. Q Those pains weren't persistent; that is, you would have them, and then you wouldn't have them for a month or two; isn't that it ? A. Yes. Q In other words, they would disappear for a month or two ? A Yes. Q Then you would have a little pain, and you would think it was rheumatism ? A. Yes. Q How long would it last when it came. ? A oh, I should say about a week, I guess. Q. You would have the pains about a week. A. Yes. 27 Q Then it would go away ? A Yes; then it would go away. Q And come back in & month or two ? A'Yes, sir. & Sometimes you wouldn't have it for two or three OF four months. A Something like that. Q Sometimes you wouldn't have it for six months ? A No: it wasn't as long as that. Q It wasn't as long as that ? A Two or three months, I should say. of You didn't do anything for that; you didn't go to a doctor? A No. of The first doctor you went to was Doctor Humphreys ? A Doctor Humphreys. Q Had you ever been to Doctor Humphreye before ? A No. e That was the first time ? A The first time I went; my sister went there with her boy. e As at matter of fact, you had only been to him once or twice, isn't that so ? A Once or twice ? 2 Yes. A. I went four times in August. Q Are you sure, now ? A He was there the first two weeks in August; he went away on his vacation and didn't come back until, I think, Labor Day; he came back Labor Day. Q Doctor Humphreys himself; you had only seen him at the most once or twice; isn't that so ? A Once or twice; no, sir. 8 You went for your X-ray, didn't you ? A I have been going there since June. e I thought he was away. A. He Was away in August. of That is what I mean. I am speaking now--- A Two weeks in August: and two weeks Doctor Phelps was there. a He was only away two weeks ? A Well, I don't know how long he was away. Q You think you had seen Doctor Humphreys personally ten or twelve times ? A Well, as to whether I have seen Doctor Humphreys; Doctor Phelps was there when Doctor Humphreys wasn't there. a Well, you know whether you had seen Doctor Humphreys personally once or twice, or ten or twelve times; you remember that. I am asking you are you sure you saw him more than once or twice. A Why, certainly. 8 You have gone to a number of dentists, though, haven't you? A I have. q The first dentist you went to was whom ? A Doctor Hodges. of Then after you left Doctor Hodges you went to Doctor Fields? A Yes; Doctor Jaffe. Q And he sent you to Doctor Fields ? A Both of them sent me to Doctor Fields. 8 That is, Doctor Hodges and Doctor Jaffe ? A Doctor Hodges and Doctor Jaffe, both. Q Did yu go to any other dentist after you left Doctor Fields ? 29 A No. of So you have just seen only three dentists ? A That is all. Q You say these dentists gave you nothing but a wash for your mouth; they didn't do any dental work in your mouth ? A Doctor Fields couldn't do it; he advised me not do. of All right; I am not disputing that fact; I am only asking these dentists didn't do anything except give you a mouth wash; is that right ? A.Yes. & When was your last child born, Mrs. Canfield ? A In March. Q Of nineteen-what ? A.1926. Q Are you taking any medicine now ? A Yes; the tonic what Doctor Humphreys gave me. of Is that bottle medicine ? A.Bottle; yes. Q Prescription ? Prescription. Q That he gave you ? A Yes; and I use a mouth wash. Q And the mouth wash ? A. Yes. 8 How often do you take Doctor Humphreys' medicine ? A Four times a day. q Four times a day ? A. Yes. q Do you just renew the bottle ? A.Yes. q That is the tonic that you referred to ? A That is the tonic, yes. & And the mouth wash, how often do you use that ? A Well, about four times, four or five times, according to the condition of my mouth; if it is very bad I use it more. 30 of Is this tonic a patented medicine ? A No; just a prescription from Doctor Humphreys. of That is, he gave you a prescription; it hasn't any name on the outside ? A No; he wrote it out the last time I was up and he told me to continue with that same prescription. Q What mouth wash do you use, or is that a prescription, too ? A Vince, I think they call it. q You buy that in the drug store ? A.Yes. q Outside of those you don't have any other medicine ? A No. of Or treatments. A.No. a Prior to the time you went to Doctor Hodges--is it Hodges, the first dentist ? I think that was the name. A Doctor Hodges, yes. Q ---Had you had any dental work done by any other dentist? A. No. Q Did you ever have any teeth filled ? A. Yes; I had a couple of teeth filled. of How long ago; can you remember ? A Well, it was right after I started to work for the Radium Company, I think, in 1917. Q Hadn't any work done after that ? A. "o. 8 The last dental work you had done was in 1917 ? A Yes. of That was the filling of some teeth ? A Well, I had this cap put on recently (indicating). Q A can on the front tooth in the upper jaw ? A. Yes. 31 Q And some fillings, too. Did you have any teeth filled ? A Yes; one tooth back there I had filled (indicating). of On the left. A. Yes. Q Rear. A. Yes; & back tooth. of The lower jaw ? A. Lower jaw tooth. of Did you have any false teeth put in ? A.. No. q That was the last time you were to the dentist, in 1917, prior to the time you went to Doctor Hodges ? A That is it. Q This painting with the brush, you say you did that and instructed the other girls to do it ? A Yes. Q Pointing the brush in your mouth ? A. Yes. 8 Between the lips. A. Yes. Q This Ruth Gegenheim, was she the forelady ? A No: she was a painter. Q She was just an ordinary painter ? A. Yes. Q But she was delegated to instruct you, is that it, when you came there ? A Yes. a By the forelady. A.Yes. Q Who was the forelady then ? A.Miss Rooney. 8 She was always the forelady when you were there ? A Always the forelady. of Was there any assistant forelady ? A Not while I was there. q Just Miss Rooney, yourself and this girl were asked by Miss Rooney to be instructors ? 32 A Yes; not only us but whe would ask different girls to go out. Q Any experienced worker would be asked to instruct the new girls ? A. That is it. Q When this Miss Gegenheim instructed you, she pointed the brush in her mouth, did she ? A Yes. Q And she told you to do it ? A. Yes. Q Did all the girls do that while you were there ? A All of them. Q Nobody stopped them ? A.No. Q Nobody said to stop ? A.No. Q Nobody said anything about it; is that right ? A No one said anything about it. 8 Nobody said it was dangerous to do it ? A No; they didn't tell me; they said it wasn't dangerous. Q You said ? A. They said it wasn't dangerous. Q Who said that ? A.Mr. Savoye. Q And he was what; the boss ? A. The boss. Q Of that department ? A Yes; boss of the whole thing; of the watch dials. Q Of the watch dial department ? A That is all there was there when I first went there. Q Whom did you hear Mr. Savoye say that it wasn't dangerous to point it that way ? A He told all the girls. Q He said it wasn't dangerous to put the brush in the mouth ? 33 A He said the radium wasn't dangerous. Q Did he tell you that ? A He told us all that. Q You were all there ? A. We were all there. Q He didn't tell any particular girl ? A They were all there; he told them all the same thing. Q How did he come to say that, do you remember at all ? How did he happen to say that ; was there any occasion for it ? A Well, I think when we first went there, of course before we had to put the brush in our mouth, the first thing we asked, "Does this stuff hurt you ?" That would be only natural; and they said no. Q Well, the one who said that would be one of the girls that was instructing you probably; is that it ? A Yes; then, I suppose, the forelady told Mr. Savoye, and Mr. Savoye then said that it wasn't, that we didn't need to be afraid, because it wasn't. Q Well, did he say it to you personally, or did you just happen to be in a group ? A When we was all there; all the girls. Q All the girls were there ? A. Yes. Q Did you hear the forelady say anything to Mr. Savoye, or are you just surmising that; you think maybe she did ? A I don't know; anyway, he said that it wasn't dangerous. Q At any rate, one day you remember distinctly, you say--- A Yes. Q That he did say to the girls, not individually, but al- together, you mean. A. Yes. Q That the radium paint wasn't dangerous. A Yes; it wasn't harmful. Q But you don't know what made him say that; he just happen- ed to say it; you don't know the occasion for saying it. A I suppose the girls were wondering, working with it and putting the brush in their mouth, naturally you don't want to put anything in your mouth that is going to hurt you. Q Can you remember when that was, when he said that ? A No; I don't remember. Q Did he say it once, or more than once, that you remember ? You can only speak from your memory, what you remember, as to whether he said it once or more than once. A Well, I don't remember. Q Did you say your sister had worked in the radium plant ? A No. & Did you have any dentist assist in the removal of the two teeth that fell out ? A No; they fellout themselves. Q Didn't need any dentist's assistance ? A See this one (indicating) ? Q That is loose, too ? A That will drop out pretty soon. Q How do you feel now; do you have any pains now ? A Well, my jaw pains me all the time. Q You just pointed to both sides; or one side ? A No; on both sides, and down here where Doctor Fields said there is pus in there, you know. 35 Q In the lower jaw ? A.Down here (indicating). Q How about the upper jaw ? A The upper jaw don't seem to bother me. Q You have pain all the time now, or only part of the time ? A No; all the time; of course sometimes it is worse than others. Q Are those the only pains you have now ? A No; I have my back. Q Your back pains you ? A. Yes. 8 All the time, or only occasionally ? A Well, it pains a little all the time, not real bad, but it gets worse at times that I am in bed. Q You are in bed with it ? A.Oh, yes. Q For how long ? A This whole side becomes paralyzed, too (indicating). Q Your right side ? A. Yes. Q Any other pains besides that now, at the present time ? A No. & Your joints don't bother you now ? A No; of course this arm has been bad in the last week (indicating). q hich arm ? A. My right arm. OF The whole arm, or just the joint ? A The whole arm seems to be, up in the (indicating). Q Right through the arm, you mean ? A Yes, it aches. Q When you try to lift it ? A Yes, it hurts when I try to lift it, you know. 36 a Have you any lack of motion in your arm; that is, can you lift it all the way up; is the motion of the arm interfered with at all ? A No; I can lift it, but it hurts. QYou can put it in the back of your head ? A Oh, yes; I can move it around all right. Q You haven't any lack of motion; but it hurts ? A It hurts when I move it. Q You haven't any pains in your knees now, or hips ? A Not just now. a Have you any help in your home, or do you take care of the work yourself ? A Well, my sister helps me; when I get down in bed I have to get somebody. Q I mean when you are not in bed; do you take care of it yourself ? A Yes; and my niece helps me. Q So that ordinarily, when you are not in bed, you do your own housework, and take care of your children ? A Well, the washing machine does that; I couldn't do it any other way. & Then when you are in bed, your niece comes in and helps you, or your sister ? A And my husband; mostly my husband; it falls on him. BY MR. SMITH: Q rs.Canfield, what I want to know is this : You say when you went there Miss Rooney was the forelady. A.Yes. Q You say she told Miss Gegenheim to instruct you in what 37 to do. A.Yes. Q Now, was it to Miss Gegenheim that you said, "Is this stuff dangerous; will it hurt us" ? Did you say that to Miss Gegenheim ? A I think so, yes; I think we asked her. Q No; I mean you; I don't mean anybody else; I mean you. A on, yes. Q You spoke to Miss Gegenheim about it ? A Miss Gegenheim. Q And you say she said it NXE wouldn't hurt you ? A That is what she said. Q You say you heard Mr. Savoye speak about it one time ? A Yes. Q Can you tell me about when that was ? A No; I don't remember when it was. Q Had you been in the employ of the company long, or a short time ? A No; a short time, I guess. Q Just a short time ? A.Just a short time. Q The occasion of that was there was a crowd of you girls together; did he come out and make a speach, or did he say it right to you directly, that this thing wouldn't hurt you? A No, he didn't say it to me directly; he said it to all the girls on the floor. q Where were they, just out on the floor ? A We were all sitting in our places. Q He came out and spoke to you all at one time ? A He came upstairs. 38 Q He came upstairs ? A Yes; where us girls were. Q What did he do; call for silence so that he could talk ? A Yes. Q And what did he say ? A He told us girls that he understood that we were a little bit leery about the radium, you know; he said that we didn't need to be, because it was harmless. Q You mean the radium paint, or the radium throughout the building ? A Well, the radium paint. Q Did you tell him that you were putting the brush in your mouth ? A Well, that is the way we were instructed to do. Q I know; but I say, did you tell him that ? A Why, he knew that we done it. Q I say, did you tell him ? ^.No, I didn't; we were talking about it and naturally thought he knew about it. Q That is what Miss Gegenheim told you. A. Yes. Taken and sworn to before me : this 17th day of January, 1929: HARRY SCHIRMER, Supreme Court Examiner. STATE OF NEW JERSEY : : SS. COUNTY OF ESSEX : RAYMOND CANFIELD, being first duly sworn accord- ing to law, on his oath deposes and says : EXAMINATION BY MR. SMITH : Q What is your full name ? A. Raymond Canfield. Q Where do you live now ? A. 370 New Street. Q How old are you ? A.34. Q When were you married ? 4.1917. Q The date ? .December 23d. Q At the same time and place that Mrs. Canfield has testified to ? Yes. Q What is your business ? A. Salesman. Q For whom ? A. Eureka Vacuum Cleaner Company. MR. MARKLEY: Is that in Newark ? A I have charge of the Irvington branch. Q When did you first notice that Mrs. Canfield was having any pains of any kind ? A Why, it was just around before Christmas, 1926. Q December ? A. Yes; just a short time before Christmas. Q Of 1926 ? A. Yes, sir. Q What were the first pains that you noticed ; what was the evidence that you noticed ? A Well, she complained that her jaws hurt her. Q Always complained of pains ? A At that time she had a very severe attack. e What did she first say the attack was ? A Well, just like a neuralgia. Q Like neuralgia ? A.Yes. Q In the face ? A. Yes. Q What did you do; anything ? A No; she used hot water bags on her jaw. Q You didn't call in the doctor ? A No. Q How often did that occur ? A Well, that was the first time I noticed anything of it. Q That was in December, 1926. A.Yes. Q When did you next notice any pains ? A Well, it was right after the first of the year. & About January 1st ? A It was right after the 1st; somewhere around January 1st. Q What pains were those ? A. The same thing. Q What part of the body ? A The same thing; well, in the jaws. Q Still in the face ? A.Ves. MR. MARKLEY: In 1927, you mean ? THE WITNESS: Yes; January, 1927. Q What part of the face were they in ? A Well, it was on both sides. Q Both sides ? A.Yes, sir. Q Still no doctor; you didn't send her to any doctor ? A No; I thought it was neuralgia. Q What did she use ? A She used hot water bags; they seemed to give more relief than anything else. Q How long did these pains last;at each attach, I mean ? A About a week. Q They last a whole week ? A Sometimes, yes; other times, why, three or four days; four days the shortest. Q What you did was to keep on using the hot water bags ? A Yes. 41 Q Did that keep on right straight from 1926 up to 1928 ? A Well, off and on, yes. Q About how often would they occur ? A Well, that I couldn't hardly say. e Well, approximately. A Because lots of times she wouldn't say anything to me. Q That you know of. A Well, I wouldn't like to say, because I couldn't. Q You see, you have to give me an estimation, in your mind; did it occur once every two months ? A Something like that, yes. Q Or once every three months ? A Every two or three months that I had noticed. Q That is what I mean; what you noticed when you came home at night, you noticed she was in pain. A Yes. of All these pains were in the face, were they ? A.Yes. Q Did you ever see a doctor for that during that time ? A Not for that, no. Q What ? A.No. Q The only thing she used was the hot water bag ? A They would seem to give her relief. 8 The hot water bag would give her relief. A.Yes. Q Did these periods or lapses of pain get longer, or short- er ? A.It would be longer. Q Don't misunderstand me; I mean--- A. You Y mean during the pain. Q I mean between pains. Suppose she had the pain this 42 week; then she wouldn't get it, you say, sometimes for, well, a month or two months, or three months. A.Yes. Q Now, did this period between pains get longer, or shorter? A The pain varied, different times. Q What would you say would be the shortest period between those attacks ? A Well, I would say this; at the start it was around every two months, the shortest. of Then what did they do, the periods between, grow longer ? A No; they didn't seem to grow longer. of Well, did they grow shorter ? A Well, at times, yes; she might have them two months, sometimes three months. Q All this time you didn't have her see any doctor at all? A Not at the first, no. Q When was the first that you saw a doctor about it ? A I don't just remember now; I think Doctor Humphreys was the first doctor. Q Doctor Humphreys was the first one ? A. Yes. Q Hadn't you heard about Doctor Humphreys before you went to him ? A Never heard of him in my life. a Never heard of him in your life ? A In fact, I didn't know she went to him until she told me. Q You hadn't discussed with her or with him about these other people working in radium factories ? A. No. 8 You hadn't discussed the situation at all ? A. No. 43 Q of course if you hadn't heard of Doctor Humphreys, you weren't the one that sent her to Doc tor Humphreys. A No. Q Didn't she discuss with you before she went to Doctor Humphreys that she was going there ? A Yes; she had mentioned his name, because her sister's little boy was treated by Doctor Humphreys. & Her sisterns little boy ? A.Yes; and at the time we weren't in very good financial straits, , so she thought she would go there to the clinic and pay a small fee. 8 What was the matter with the boy ? A I don't just remember. Q I mean, was it just medical, or was it joint trouble and medical ? A No; just bones, I think it was; crippled bones. Q I mean, did he have some trouble with his bones; the boy? A Well, he was bowlegged, I think it was; I think he had his legs straightened. Q That is how you came to go to Doctor Humphreys. A. Yes. Q You were married in 1917, were you ? A. Yes, sir. Q December 23d, 1917 ? A. Yes. Q During all that time your wife worked at the Radium Company, did she ? A.Yes. She worked there about a month after we were married. Q After you were married. A.Yes. Q She left in January, or February ? A It was around that time; the last of January or the beginning of February, I think. 44 BY MR. MARKLEY: Q Have you any statement of what expenses you had ever since you have been to the doctors ? A Well, no, not just itemized out. Q I understand the first doctor or dentist was Doctor Hodges? A Yes. Q Do you know what his bill was ? A No; I don't; she has taken care of that. Q She took care of that . Yes. Q Did you pay anything, do you know ? A Yes; he was paid. of You don't know how much. A.No; I didn't ask her how much. Q How about Doctor Jaffe ? A I don't know what his bill was. Q And Doctor Fields ? A $25. is what he charges for X-rays; they are $25. Q Doctor Fields charges $25. for X-rays ? A. Yes, sir. Q Doctor Humphreys, has he been paid, do you know ? A Well, we paid the clinic fees there; I don't remember. Q You don't know what they are. A'No. Q You are manager, you say, of the Irvington branch of the Eureka Vacuum Cleaner Company. A. Yes, sir. Q You said you were also a salesman; you mean a salesman in the branch store ? A No; I am managing this branch store. Q You manage the branch store; you don't go out yourself. A No. & You just stay there. A Yes; I go out, not selling for myself, but training the men; helping them. Q You take the men around and show them how to do it. A That is it. Q Are you on a salary, or commission ? A. Both. q Can you give me your average earnings ? A Well, it varies anywhere from fifty to seventy-five dollars. Q A week ? A. Yes. Q You average between fifty and seventy-five dollars. A Yes, sir; at the present time. Q How long have you been there, Mr.Canfield ? A I have been with these people since last June. Q June, 1928. A Yes; but this just job, I have just been promoted the first of the year. Q You have just been promoted to manager. A.Yes. Q Prior to what what were you ? A.Salesman. Q Outside salesman ? A.Yes. Q You live with your wife and three children, don't you ? A Yes. Q Anybody else in the family, in your immediate household ? A No. Q Just you five. A.Yes, sir. Q Your wife ordinarily does the housekeeping, except when she is laid up ? A She does what she can, yes. Q When she is laid up, you help, and her sister helps and her niece helps. 46 A The oldest boy is quite a help around the house, too. Q How old is he now ? A Well, he is ten now. She made a mistake. of What did she say he was ? A I think she said nine. Q Are there three boys ? A.No;two boys and a girl. Taken and sworn to before me : this 17th day of January, 1929: HARRY SCHIRMER, Supreme Court Examiner. STATE OF NEW JERSEY : : SS. COUNTY OF ESSEX : MAE CUBBERLY CANFIELD, being recalled for further examination, on her oath deposes and says : EXAMINATION BY MR. SMITH : Q Can you tell us about how much you paid Doctor Hodges; about what you paid him ? .Doctor Hodges ? 8 Yes. A.I paid him for one visit. of How much was that ? A.I think $2. Q And Doctor Jaffe ? A. Doctor Jaffe, I think, was $1. I don't remember. Q And Doctor Fields ? A. Well, Doctor Fields, he charged me five dollars, but he usually charges $25; I told him I couldn't afford that. Q But he charged you five A.Yes. Q Have you paid Doctor Humphreys anything ? A No, I haven't paid him at all. Q Those are the only doctors that you have had ? 47 A Yes. of The only things that you paid. A Yes. Taken and sworn to before me : this 17th day of January, 1929: HARRY SCHIRMER, Supreme Court Examiner. I, Harry Schirmer, a Supreme Court Examiner of the State of New Jersey, do certify that the fore- going is a true and accurate transcript of the examin- ation of the plaintiffs in the above entitled cause, taken by and before me at the time and place herein- before mentioned; and I believe said transcript fair- ly and accurately states the testimony given. HARRY SCHIRMER, Supreme Court Examiner.

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    "ocrText": "NEW JERSEY SUPREME COURT\nESSEX COUNTY.\nMAE CUBBERLY CANFIELD et al.\nPlaintiffs,\nACTION AT LAW.\nEXAMINATION BEFORE TRIAL.\nVS.\nU. S.RADIUM CORPORATION,\nDefendant.\nBefore\nHARRY SCHIRMER. SUPREME COURT EXAMINER.\nINDEX\nDirect\nCross\nRe-Direct\nRe-Cross\nMae Cubberly Canfield\n2\nRaymond Canfield\n38\nMae C. Canfield, rec.\n46\nHARRY SCHIRMER\nLaw Stenographer\nSupreme Court Examiner\nI Exchange Place\nJersey City, N.J.\nfees OF EXAMINER.\nOne session fee\n$6.00\nAdministering two oaths\n.50\nDepositions, 116 fols.\n34.80\nCertificate\n.50\n$41.80\nHARRY SCHIRMER,\nSupreme Court Examiner.\n1\nNEW JERSEY SUPREME COURT\nESSEX COUNTY.\nMAE CUBBERLY CANFIELD\n:\nand RAYMOND CANFIELD,\n:\nPlaintiffs,\n:\nACTION AT LAW.\nVS.\n:\nEXAMINATION BEFORE TRIAL.\nU. S. RADIUM CORPORATION,\na corporation of the State of :\nDelaware,\nDefendant.\n:\nExamination of plaintiffs in the above entitled cause\nbefore trial, taken before me, Harry Schirmer, a Supreme Court\nExaminer of the State of New Jersey, at the office of Messrs.\nPotter de Berry, 60 Park Place, Newark, New Jersey, this\nseventeenth day of January, 1929, at four o'clock in the\nafternoon, under Section 144 of the Practice Act of 1903,\nas amended, pursuant to order.\nAppearances:\nMessrs. Potter de Berry,\nAttorneys for Plaintiffs;\nMessrs. Collins de Corbin, (Mr. Markley),\nMessrs. Edwards de Smith (Mr. Smith),\nAttorneys for Defendant.\nIt is stipulated that the examination be taken\nstenographically and the signatures of the\nwitnesses waived.\n2\nSTATE OF NEW JERSEY :\n: SS.\nCOUNTY OF ESSEX :\nMAE CUBBERLY CANFIELD, being first duly sworn\naccording to law, on her oath deposes and says :\nEXAMINATION BY MR. SMITH:\nQ Mrs. Canfield, what is your full name ?\nA Mae Cubberly Canfield.\nQ. Where do you live ? A. Now ?\nQ Now. A. At 370 New Street, Newark.\nQ Are you married ? A. Yes.\nQ What is your husband's name ? A. Raymond Canfield.\nQ Where were you married ? A. In East Orange.\nQ And when ? A. December 23d, 1917.\nQ In a church ? A. No; in the parsonage.\nQ Who was the minister ? A. Reverend Giles.\na And how old are you ? A. 37.\nQ Have you any children ? A. Yes; three.\nQ Three ? A. Three children.\nQ, What are their names; give me the names and ages of each ?\nA Pershing, ten years; Raymond, seven years; and Patricia\ntwo and a half years.\nQ They are all living ? A. Yes.\nQ They live with you, I presume, don't they ? A. Yes.\nQ All in good health ? A. Yes.\n3\nQ You worked for the U. S. Radium Company ? A. 1 did.\nQ When did you first go into their employ ?\nA In 1916.\nQ Where was its place of business then ?\nA On Third Street.\nQ Newark ? A. Newark.\nQ What position did you have then ? A. Dial painter.\nQ Dial painter ? A. Dial painter, yes.\nQ Who was your immediate superior ?\nA Miss Rooney was our floorlady, and Mr. Savoye was really\nthe boss of that plant.\nQ What date did you go into their service, do you know ?\nA 1916.\nQ Do you know what month ?\nA I think it was in September.\nQ How long did you remain dial painting for them ?\nA 1 was there until 1 left, 1918.\nQ In left when ? A. In 1918.\nQ Were you continuously dial painting ?\nA Yes;I was dial painting.\nQ All the time ?\nA Well, I was instructor; when they moved up to the Orange\nplant, why, I instructed girls; they had hired some new girls\nwhen they moved up there, so Mr. Saro ye sent me up there to\n4\nhire girls and instruct them in the painting for about two\nweeks, I guess.\nQ You hired them and instructed them? A. Yes.\nQ While you were dial painting, vil 11 you just tell me what\nyou did; just how did you do it ?\nA Well, we put the brush in that crucible with the radium\nin, painting numerals on the watches.\nQ What size crucible was there in front of you ?\nA Well, I should say about like that (indicating), a small,\nlittle crucible.\nQ What is the size of that; about the size of a quarter ?\nA I guess so; they were very small; not a large amount of\nradium fot them at a time.\nQ How deep were they, would you say ?\nA Well, 1 guess sbout that (indicating).\nQ About an inch ? A. About an inch, I guess.\nQ. Did you put the stuff in it yourself ?\nA Oh, yes; it was given to us in little bottles, they we\nput it in the crucible, put so many drops of color, then so\nmany drops of water, then mixed the stuff; when it was nice\nand smooth, then we paint with it.\nQ Then you mixed it yourself ? A. Yes.\nQ How did you mix it; with the brush ?\nA No; with a little glass mixer.\n5\nQ That is just like a glass stylus that you turn it around\nwith ? A. Yes.\nQ This brush that you had, what was it, a camel hair brush?\nA A camel hair brush.\nQ How large was it ?\nA Well, 1 guess they were about like that (indicating).\nQ About eight inches long ?\nA Well, something like that, I guess.\nQ What was the handle made of; wood ?\nA Yes; wood.\nQ Then it had the camel hair at the end ?\nA Yes, at the end.\nQ Were they pointy brushes ?\nA No; they were just ordinary brushes, you know, that you\nuse when you paint things in books, you know, children's books\nQ But the end of the brush was pointy; it wasn't flat across?\nA Well, it wasn't a real pointy brush.\nQ Having mixed the preparation, you say you put the brush\nin and then painted the dials ?\nA And painted the dials, yes.\nQ Was it the dial you painted, or just the numerals on\nthe dials ?\nA The numerals on the dial.\nQ When did they move from Third Streetate Orange ?\n6\nA In June, of 1917.\nQ In June, 1917 ? A. Yes.\nQ You went with them ? A. Yes.\nQ How long did you work for them at Orange ?\nA From that time until 1918.\nQ From that time until 1918 ? A. Yes.\nQ In what month did you quit, in 1918 ?\nA I think it was in March.\nQ In March, 1918 ?\nA Yes; either the latter part of February or the first of\nMarch.\nQ When you say you instructed the girls up there, just tell\nme how you instructed them ?\nA Well, of course, they had what they call brass dials.\nQ Yes. A. Which was on a long strip, about eight on a strip\nlittle watches; then, of course, we used some kind of\nimitation radium, it wasn't radium, you know, it wasn't\nthe real stuff, because you couldn't do that, you mix it\njust the same as radium.\nQ Yes. A. Then they had a glass of water with a little\ncrucible, and the glass of water was to wash your brush off,\nbecause the radium used to harden, you know, on the brush,\nand then you couldn't use it, then you dip it in the water\nand shake it off, then put the brush in your mouth and\n7\npoint it, then dip it in the radium and then paint the dial.\nQ You put the brush in your mouth ? A. Oh, yes.\nQ And you instructed the girls to put the brush in their\nmouth ?\nA 1 was instructed that way; 1 didn't know any other way.\nof Did you say you were instructed ? A. Why, surely.\nQ Who instructed you that way ?\nA Well, the girl's name, 1 think, was Ruth Gegeheim.\nQ She was your instructress ? A. Yes, sir; she instructed\nme.\nQ Where was she employed; at Third Street ?\nA At Third Street.\nQ That was when; in 1916 ?\nA That was in 1916.\nQ In 1916 ? A. Yes.\nor What instructions did she give you relative to putting\nthe brush in your mouth ?\nA Well, we couldn't, you know, paint with the brush, it\nwould spread as we were painting; it would spread, you know.\nQ Yes.\nA And unless you put the edge in your mouth you couldn't\nget a decided point, and the point had to be a decided point\nto paint the numerals, because if you didn't have a point\nit would go on the outside then.\n8\nQ Then you did that in order to point the brush ?\nA Yes.\nQ You couldn't point the brushes in this glass of water\nthat you said was there ? A. No.\nQ Why ?\nA Well, you couldn't dip it in, there would be water on the\nbrush.\nQ Then, because water was on the rush, is the reason you\ncould not point it, is that it ?\nA No; you would shake the water out, but it wouldn't be\npointy; you had to have it 80 it would stick together.\nQ In other words, you would have to have the brush 80 that\nthe brush would stick together into a fine point.\nA Yes; otherwise if you put it into the radium like that it\nwould be a little full, you know, it would be too full and\nit would paint a big spot on the dial instead of the number.\nQ, It was Miss Ruth Gegenheim who instructed you?\nA As I remember; Miss Rooney was our forelady.\nQ Was it Miss Rooney, or Miss Gegenheim ?\nA Miss Gegenheim; because Miss Rooney was the forelady;\nshe didn't know how to paint; if any new girl came she would\nsay, \"You go up and teach the new girl how to paint the\ndials\".\nQ As I understand you, you left there in 1918.\n9\nA 1918; yes.\nQ Were you married before you went there, or after you\nwent there ?\nA No, after I went there; I was married in December, 1917;\nthe 23d of December.\nQ How much did you earn ?\nA What is that ?\nQ How much did you eark a week ?\nA We were on piece work.\nQ You mean that you were paid by the piece ?\nA Paid by the watch.\nQ By the watch ?\nA Yes; I think it was one cent and a half for a Yankee\nand two cents for the Midget.\nQ Of course the more watches you painted, the more you\nearned ?\nA The more money you earned; yes, sir.\nQ Can you give me an idea about what that was ?\nA What do you mean ?\nQ About what you earned a week.\nA Well, 1 seen the time that I made $30. when we worked\novertime; about $25. I averages, I guess, twenty or twenty-\nfive dollars, on an average; of course the other is when we\nworked overtime.\n10\nQ Then I understand you left there in 1918. A. Yes.\nQ And haven't been back to work for them since.\nA No.\nQ When did you first notice any pains about yourself ?\nA In November, 1926.\nQ November, 1926 ? A. Yes.\nQ That is the first you had ?\nA Yes; that is the first I had.\nQ Where were they ?\nA Well, they were in my joints; I thought 1 had Theumatism.\na Your joints ?\nA Yes; my jaw joints.\nQ You thought you had rheumatism. A. Yes.\nQ Did you go to a doctor ?\nA Well,no, 1 didn't go to a doctor; it wasn't so bad, you\nknow, as that.\nQ You just took home remedies/ A. Yes.\nQ As I understand you, what you mean is that the first pains\nyou had were in November, 1926. A. Yes.\nQ You hadn't had any prior to that time ?\nA No; I was in perfect health.\nQ You were in perfect health ? A. Yes, always.\nQ All the way up to 1926. A. Yes, sir.\n11\nQ The first pains were in November, and those were pains\nin the joints, you say ?\nA Yes, in some of my joints, and in my back.\nQ What kind of pains were they ?\nA Well, kind of sharp pains, or rheumatic pains, as we\ncalled them.\nQ Were they sharp, or just dull ?\nA Well, sharp at some times, you know, kind of shooting\npains.\nQ When did you go to see the doctor first ?\nA Well, I didn't go to the doctor until, it was in June,\nof 1928.\nQ You hadn't gone to a doctor until June, 1928 ?\nA Yes.\nQ All that time you had been having those pains, you say ?\nA Well, off and on; not bad.\na Where did the pains first appear in the joints ?\nA Well, my jawbone seemed to hurt.\nQ Which one ?\nA All around, on both sides.\na All around; that is the lower jaw ?\nA The lower jaw.\nQ That seemed to pain all the time, you say ?\nA No, not at first.\n12\nQ You mean all the way around the jaw ?\nA Not at first, it didn't pain all the time until this\nFebruary.\nQ Where was it first starting to pain ?\nA When was it ?\nQ, On the left side ?\nA No; on the right side.\nQ On the right side ? A. Yes.\na Is that at the joint of the jawbone ?\nA Yes, right in here (indicating).\nMR. MARKLEY: She is indicating a place a little\nbit below the joint.\nQ You mean at the joint, or in between the joint and the\nfront part of your jaw ?\nA No, right in here, you see, right around here (indcating)\nQ That is not at the hinge ?\nA Well, right in here, I guess there is the hinge (indicat-\ning).\nor Is that what you mean ? A. Yes.\nQ You mean from the joint around toward the front of the J an?\nA Yes.\nMR. MARKLEY: That is the right lower jaw ?\nTHE WITNESS: That is right.\nQ What kind of pains were they when they first came ?\n13\nA Well, they seemed to be a set pain, kind of an ache.\nQ Just like an ache ?\nA Just like an ache.\nQ It didn't interfere with the motion of the jaw at all,\ndid it ?\nA Well, up in here, where these bones come together here,\nwhy, you know, it felt funny, well, 1 don't know, as if it\nwas, 1 can't explain that (indicating).\nMR. MARKLEY: The witness is referring now to\nthe lower right jaw, right below the ear.\nTHE WITNESS: Yes.\nQ That is at the right joint ?\nA Yes; right.\nQ You say it felt funny; will you just explain that as\nnearly as you can ?\nA Well, it felt like a knock or something in it.\nQ Like a knock in it ?\nA Like a knock in it; it was a peculiar feeling.\nQ And that lasted for how long ?\nA Oh, I guess about two weeks.\nQ About two weeks ? A. Yes.\nQ Did it go away ?\nA Yes, then it went away.\n14\nQ What other pains did you have in the jaw ?\nA In the jaw ?\nQ Yes. A. Only just the ache in the jawbones.\nQ Just the ache ?\nA Yes; then my gums, they were filled with pus, you know,\nthey were swollen.\nQ The gums swollen ? A. Yes.\nQ Now, did you go to the doctor about that knock in the jaw?\nA Yes; 1 went to Doctor Humphreys.\nQ How did you come to go to Doctor Humphreys ?\nA Well, my sister told me to go there, because she had her\nlittle boy over there and said it was good over there, so\nour money was kind of scarce, I couldn't go to a regular\ndoctor.\nQ You don't mean that. A. You know what I mean.\nQ What is your sister's name ? A. Mrs. Carsey .\nQ How do you spell it ? A. C-a-r-s-e-y.\nQ Doctor Humphreys is at the hospital, you mean, don't you ?\nA Orthopoedic, yes; I went to the clinic.\na How often did you go to Doctor Humphreys ?\nA Well, when I was real bad I went every week; then when I\ngot better I would go every two weeks, when 1 wasn't so bad.\na When was the first you went to him ? A. In June.\nQ This was the first ? A. Yes.\n15\nMR. MARKLEY: 1928 ?\nTHE WITNESS: 1928.\nQ What did he do for you ? A. Well, he gave me tonics.\nQ Anything else ?\nA No; he said that is about the only thing to do, to keep\nthe blood in; get the blood up.\nQ, Can you give me an estimation of the number of visits you\nmade to Doctor Humphreye ?\nA No, I couldn't say; I don't know; since June.\nQ Just approximate, that is all.\nA Well, I don't know; maybe twelve times.\nQ Twelve times ? A. Maybe more; I don't know.\nQ Each time he just prescribed tonics ?\nA Well, yes, just to change it; once in a while he would\nchange the tonic, give me a little different one.\nQ is he the only doctor you went to ?\nA No; then 1 went to a dentist.\nQ Who is that ? A. Doctor Hodges.\nQ Where is his place ?\nA He is on Central Avenue and Bergen Street.\nQ. When did you first go to him ?\nA Well, 1 think it was in September; then Doctor Fields; 1\nwent to Doctor Fields.\nIR. MARKLEY: September, 1928 ?\nTHE W TNESS: Yes.\n16\nQ, Doctor Fields ? A. Yes.\nQ He is also a dentist ? A. Yes.\nQ Doctor Hodges, what did he do for you ?\nA Well, he gave me a prescription to use in my mouth.\nQ That is a mouth wash, you mean ?\nA Yes, to hold in my mouth, you know, to relieve the pain,\nand also the pus, that was in the jaw, in the gums.\nQ Anything else that he did for you ?\nA No; he wouldn't touch my teeth.\nQ How did Doctor Fields treat you ?\nA Well, he wouldn't, either.\nQ. He didn't touch them ? A. No.\nQ Did he give you any wash ?\nA No; 1 told him what Doctor Hodges was doing, and he said\nthat was all right.\nQ Then from the time that you say you first felt this\npain, you haven't had any treatment of the mouth except the\nwashes and the tonics ?\nA Just the tonics and the washes; yes.\nQ You had no teeth pulled, or no operations of any kind ?\nA No; the teeth fell out themselves; two teeth fell out\nby themselves.\nQ What two teeth ?\nA One down here on the lower jaw and one up there (indicat-\n17\ning).\nQ One upper and one lower ? A. Yes. This one is ready to\nfall out (indicating).\nQ When did they fall out ?\nA This one down here fell out a year ago (indicating),\nin December; that would be December, 1927.\nQ Yes; and the upper ?\nA And the other fellaw out----\nMR. MARKLEY: You are speaking of the lower;\nthat is the lower fell out in December, 1927 ?\nTHE WITNESS: In December, 1927; and this one\nfell out, I think it was in September or\nOctober, 1928.\nQ That is the upper ? A. yes.\nQ Have you been working; do you work outside of your own\nhome work ? A. Just housework.\nQ Just housework ? A. Yes.\na Taking care of your children, and so forth. A. Yes.\nQ You say you used to go to Doctor Humphreys once a week,\nand then later on once every two weeks; when was the last\ntime you saw him?\nA I think it was the last the first week in December, I\nthink, of 1928.\nQ When was the time before that; the last time before that\n18\nA It was in November some time.\nQ How many times in December did you go; once ?\nA Once in December, yes.\nQ And in November ?\nA I think I went a couple of times in November.\nQ And before that ? A. In August, I think, I went.\nQ How many times did you go in August ?\nA 1 think 1 went--yes, 1 went every week in August, because\nтухи gums were 80 bad then ; Doctor Humphrsys wasn't there;\nDoctor Phelps was there.\nQ Phelps ? A, Doctor Phelps.\nQ, He is in Doctor Humphreys' office ?\nA Yes; he and Doctor Humphreys are together.\nQ As I understand you, the first time you saw Doctor Humphrey\nwas in June, 1928 ? A. Yes; June, 1928.\nQ Had you seen any other doctor before him ? A. No.\nQ You haven't had any doctor for those pains that you said\nyou had, rheumatic pains, or anything like that ?\nA Well, I had a doctor in February.\nQ Who was he ? A. Doctor Green.\nQ That is 1928 ? A. In 1928.\nQ Doctor Green. A. Yes.\nQ What was he, a medical man, or dentist ?\nA No; he is a medical doctor.\n19\nQ. Where is his place ? A. On Bank Street here.\nQ Bank ? A. Yes.\nQ That is Newark ? A. Yes, Newark.\nQ, What did he do for you; just gave you medicine ?\nA Just gave me medicine, because I don't know at the time\njust what he was doctoring me for.\nQ What ? A. 1 don't know at the time, about that time;\nthat was in February.\nQ February of 1928 ? A. 1928.\nQ You didn't know what ? A. I didn't know about the\nradium, you know, until I went to see Doctor Humphreys, you\nsee.\nQ Did Doctor Humphreys X-ray you ? A. Yes; he X-rayed me.\nQ Did any other doctor X-ray you ? A. Doc tor Fields.\nQ. When was that ; just here lately ?\nA Yes; I think it was in October.\nQ Where did you live prior to your present address ?\nA Where did I live before that ?\nQ Yes. A. On Sixteenth Avenue.\nQ Sixteenth Avenue where ? A. 177.\nQ. Sixteenth Avenue, Orange ? A. No; Newark.\nQ And where before that ? A. On South Seventh Street.\nQ Newark, again ? A. Yes; always in Newark.\nA How long did you live in Sixteenth Street ?\n20\nA On Sixteenth Avenue ?\nQ Yes. A. About a year.\nQ And in South Seventh Street ? A. About a year.\nQ What was the number on South Seventh Street; can you\ngive me that ? A. 180.\nQ Had you been to see Doctor Jaffe ? A. Yes.\nQ When did you see him ? A. 1 think it was in October\n#\nQ 1928 ? A. Yes; 1928.\nQ What is he, a dentist ? A. He is a dentist, yes.\nQ Where is his place ? A. Market and Broad.\nQ What did he do; just make an X-ray of you ?\nA No; he didn't make an X-ray.\nQ What did he do ? A. He sent me to Doctor Fields.\nQ And that is all ? A. Yes.\nQ He didn't examine you ?\nA Yes; he looked at my teeth and told me that he didn't\nknow really what to do for me, to see Doctor Feields.\nQ Have you seen Doctor Blum e ? A. No; 1 haven't gone over\nto see him yet.\nBY MR. MARKLEY:\nQ What is your weight, Mrs. Canfield ?\nA Well, I guess about 142.\nQ, And your height ? A. I don't know how tall 1 am; five\nfoot something; I don't know.\n21\nQ Do you mind just standing up a moment ?\nA (The witness stands as requested).\nMR. MARKLEY: About five foot three.\nQ When did you start to work for the Radium Company ?\nA When ?\nQ Yes. A. In 1916.\nQ What time in 1916; in September, 1 think you said ?\nA Sometime in September; the latter part of September, 1\nthink it was.\nQ Prior to that had you worked somewhere else ?\nA I worked for the L. S. Plaut Company, Newark; department\nstore.\na How long had you worked there ?\nA oh, I don't know; about a year, I guess.\nQ Prior to that had you worked somewhere ?\nA Well, I worked for a dressmaker; you see, I was dressmaker\nin L. S. Plaut & Company.\nQ And you were a dressmaker for somebody else prior to that?\nA Yes;Mrs. King her name was.\nQ Mrs. King ? A. Yes; she was a dressmaker.\nQ Where is she ? A, She lived on Twelfth Street; 1 think\nit was 179 South Twelfth Street.\nQ In Newark ? A. In Newark, yes.\nQ Was that your first employment ? A. Yes.\n22\nQ And when was that; how long ago; when did you start to\nwork for her ? A. Oh, 1 don't know.\nQ Was that your first job, so to speak ?\nA No, I worked with different dressmakers, you know, learn-\ning the trade; that is different ones, you know; first I\nwould be with one, see, like that; 1 remember one party up\nin East Orange somewhere; 1 don't remember her name.\nQ When you left the Radium Company, you left there of your\nown accord ? A. Yes.\nQ You resigned your position ? A. I was married, yes.\nQ You worked there after you were married, didn't you ?\nA Well, I worked there for a few months after I was married;\nMr. Saw ye wanted me to stay; that is the reason I stayed.\nQ Let me see; you were married when ? A. In 1917.\nQ In December, wasn't it ?\nA Yes; December 23d; then Mr. Savoye asked me if I would\nstay with him, and 1 told him yes.\nQ And you worked until February, 1928 ?\nA Yes; either February or March; 1 don't just remember.\nQ The last of February or the first of March ?\nA Yes; some where around there.\nQ In 1918. A. Yes.\nQ Then you quit. A. Yes.\nQ Did you work any place since then ? A. No.\n23\nQ Other than keeping your home. AN No.\nQ Did you ever do any radium painting for any other employer?\nA 1 didn't know what it was.\nQ The only place you did radium painting was---\nA Yes; 1 was a dressmaker.\nQ. ---With the U. S. Radium Company. A. Yes.\nQ Were you to any other doctors or doctor than those you\nhave named, prior to this time, for any treatment or sickness\nor illness ? A. No.\nQ You were always healthy ? A. I was always healthy.\nQ From 1918 right on through, up until when did you say\nyour trouble began ? A. In 1926.\nq What time;in November, 1926 ?\nA Yes; November.\nQ Up until November, 1926, you were in perfect health ?\nA Yes.\nQ Did you have any doctors ? A. No.\nQ Did you have any severe illnesses ? A. No.\nQ Are you sure, now ? You just think back there and try\nto see if you remember any.\nA Nothing; I had three children, that is all; that is\nnothing severe.\nQ Did you ever have whooping cough ? A. Not that I rmmember.\nQ Did you have influenza ?\n24\nA Influenza , I think I had the influenza in 1918.\nQ When the spidemic was on ?\nA When the epádemic was going around.\nQ What time, do you remember when that was ?\nA In 1918.\nQ In October ? A. Right after my baby was born.\nQ The epidemic was in October and November.\nA In October.\nQ When was the baby born ? A. September 18th.\nQ You had the influenza right after that ?\nA Yes; when he was two weeks old.\nQ How long were you laid up with the influenza at that time?\nA Well not very long.\nQ A few weeks ? A. Yes; a week and a half, 1 guess.\nQ Did you go to the hospital ? A. No.\nQ You had the doctor at your home ? A. Surely.\nQ What doctor did you have ? A. Doctor Brown.\nQ Where; of Orange ? A. No; Newark.\nQ What is his first name, do you know ?\nA (No answer).\nQ Where is his office ?\nA On Roseville Avenue somewhere; he was the one I had when\nthe baby was born.\nQ Don't you remember having whooping cough ?\n25\nA No; I don't remember having the whooping cough.\nQ Did you have measles ?\nA Not that I can remember; I may have had them; if I had\nthem, I had them before I can remember.\nQ You don't remember having measles ?\nA No, sir; I was always healthy; of course I don't know\nwhether I had measles or not.\nQ Your three children are living, aren't they ? A. Yes.\nQ Have you any deceased children ? A. No.\nQ Your mother, is she living ? A. No, she is dead.\nQ When did she die ? A. oh, dear, I don't know.\nQ How long ago, approximately ?\nA About twenty years ago, 1 guess; more than that, 1 guess;\nshe died when 1 was a child.\nQ What was her age, about, do you know, when she died ?\nA 44; she died with the change of life.\nQ This trouble that you say you first had, with these pains--\nA In November, 1926.\nQ Where did you first have the pains ?.\nA Well, in my joints and my back.\nQ What do you mean by your joints ?\nA Well, my hips, in my hip joints here, and my knees,\nmy knee joints, and my back.\nQ You ha d pains in your knees and pains in your hip ?\n26\nA Yes.\nQ, And pains in your back ? A. Yes.\nQ Which did you have first ? A. I think in my knees first.\nQ How long was it after you had those that you got pains\nelsewhere ?\nA Well, I don't just recall; 1 know after that, why, my\nback started here, my back started, it hurt, and my hip.\nQ You didn't go to a doctor for this at all ?\nA No, I didn't go to the doctor, because everybody said\nit was rheumatism, so naturally it wasn't as bad.\nQ You didn't do anything for those pains ? A. No.\nQ And the first time you went to a doctor was when ; when\nyou went to Doctor Humphreys ? A. Yes; in June.\nQ In June,1928 ? A. 1928.\nQ Those pains weren't persistent; that is, you would have\nthem, and then you wouldn't have them for a month or two;\nisn't that it ? A. Yes.\nQ In other words, they would disappear for a month or two ?\nA Yes.\nQ Then you would have a little pain, and you would think\nit was rheumatism ? A. Yes.\nQ How long would it last when it came. ?\nA oh, I should say about a week, I guess.\nQ. You would have the pains about a week. A. Yes.\n27\nQ Then it would go away ?\nA Yes; then it would go away.\nQ And come back in & month or two ? A'Yes, sir.\n& Sometimes you wouldn't have it for two or three OF four\nmonths.\nA Something like that.\nQ Sometimes you wouldn't have it for six months ?\nA No: it wasn't as long as that.\nQ It wasn't as long as that ?\nA Two or three months, I should say.\nof You didn't do anything for that; you didn't go to a doctor?\nA No.\nof The first doctor you went to was Doctor Humphreys ?\nA Doctor Humphreys.\nQ Had you ever been to Doctor Humphreye before ?\nA No.\ne That was the first time ?\nA The first time I went; my sister went there with her boy.\ne As at matter of fact, you had only been to him once or\ntwice, isn't that so ?\nA Once or twice ?\n2 Yes. A. I went four times in August.\nQ Are you sure, now ?\nA He was there the first two weeks in August; he went away\non his vacation and didn't come back until, I think, Labor\nDay; he came back Labor Day.\nQ Doctor Humphreys himself; you had only seen him at the\nmost once or twice; isn't that so ?\nA Once or twice; no, sir.\n8 You went for your X-ray, didn't you ?\nA I have been going there since June.\ne I thought he was away. A. He Was away in August.\nof That is what I mean. I am speaking now---\nA Two weeks in August: and two weeks Doctor Phelps was there.\na He was only away two weeks ?\nA Well, I don't know how long he was away.\nQ You think you had seen Doctor Humphreys personally ten or\ntwelve times ?\nA Well, as to whether I have seen Doctor Humphreys; Doctor\nPhelps was there when Doctor Humphreys wasn't there.\na Well, you know whether you had seen Doctor Humphreys\npersonally once or twice, or ten or twelve times; you\nremember that. I am asking you are you sure you saw him\nmore than once or twice.\nA Why, certainly.\n8 You have gone to a number of dentists, though, haven't you?\nA I have.\nq The first dentist you went to was whom ?\nA Doctor Hodges.\nof Then after you left Doctor Hodges you went to Doctor Fields?\nA Yes; Doctor Jaffe.\nQ And he sent you to Doctor Fields ?\nA Both of them sent me to Doctor Fields.\n8 That is, Doctor Hodges and Doctor Jaffe ?\nA Doctor Hodges and Doctor Jaffe, both.\nQ Did yu go to any other dentist after you left Doctor Fields ?\n29\nA No.\nof So you have just seen only three dentists ?\nA That is all.\nQ You say these dentists gave you nothing but a wash for\nyour mouth; they didn't do any dental work in your mouth ?\nA Doctor Fields couldn't do it; he advised me not do.\nof All right; I am not disputing that fact; I am only asking\nthese dentists didn't do anything except give you a mouth\nwash; is that right ? A.Yes.\n& When was your last child born, Mrs. Canfield ?\nA In March.\nQ Of nineteen-what ? A.1926.\nQ Are you taking any medicine now ?\nA Yes; the tonic what Doctor Humphreys gave me.\nof Is that bottle medicine ? A.Bottle; yes.\nQ Prescription ? Prescription.\nQ That he gave you ?\nA Yes; and I use a mouth wash.\nQ And the mouth wash ? A. Yes.\n8 How often do you take Doctor Humphreys' medicine ?\nA Four times a day.\nq Four times a day ? A. Yes.\nq Do you just renew the bottle ? A.Yes.\nq That is the tonic that you referred to ?\nA That is the tonic, yes.\n& And the mouth wash, how often do you use that ?\nA Well, about four times, four or five times, according to\nthe condition of my mouth; if it is very bad I use it more.\n30\nof Is this tonic a patented medicine ?\nA No; just a prescription from Doctor Humphreys.\nof That is, he gave you a prescription; it hasn't any name on\nthe outside ?\nA No; he wrote it out the last time I was up and he told me\nto continue with that same prescription.\nQ What mouth wash do you use, or is that a prescription, too ?\nA Vince, I think they call it.\nq You buy that in the drug store ? A.Yes.\nq Outside of those you don't have any other medicine ?\nA No.\nof Or treatments. A.No.\na Prior to the time you went to Doctor Hodges--is it Hodges,\nthe first dentist ? I think that was the name.\nA Doctor Hodges, yes.\nQ ---Had you had any dental work done by any other dentist?\nA. No.\nQ Did you ever have any teeth filled ? A. Yes; I had a\ncouple of teeth filled.\nof How long ago; can you remember ?\nA Well, it was right after I started to work for the Radium\nCompany, I think, in 1917.\nQ Hadn't any work done after that ? A. \"o.\n8 The last dental work you had done was in 1917 ?\nA Yes.\nof That was the filling of some teeth ?\nA Well, I had this cap put on recently (indicating).\nQ A can on the front tooth in the upper jaw ? A. Yes.\n31\nQ And some fillings, too. Did you have any teeth filled ?\nA Yes; one tooth back there I had filled (indicating).\nof On the left. A. Yes.\nQ Rear. A. Yes; & back tooth.\nof The lower jaw ? A. Lower jaw tooth.\nof Did you have any false teeth put in ? A.. No.\nq That was the last time you were to the dentist, in 1917,\nprior to the time you went to Doctor Hodges ?\nA That is it.\nQ This painting with the brush, you say you did that and\ninstructed the other girls to do it ?\nA Yes.\nQ Pointing the brush in your mouth ? A. Yes.\n8 Between the lips. A. Yes.\nQ This Ruth Gegenheim, was she the forelady ?\nA No: she was a painter.\nQ She was just an ordinary painter ? A. Yes.\nQ But she was delegated to instruct you, is that it, when\nyou came there ?\nA Yes.\na By the forelady. A.Yes.\nQ Who was the forelady then ? A.Miss Rooney.\n8 She was always the forelady when you were there ?\nA Always the forelady.\nof Was there any assistant forelady ?\nA Not while I was there.\nq Just Miss Rooney, yourself and this girl were asked by\nMiss Rooney to be instructors ?\n32\nA Yes; not only us but whe would ask different girls to\ngo out.\nQ Any experienced worker would be asked to instruct the\nnew girls ? A. That is it.\nQ When this Miss Gegenheim instructed you, she pointed the\nbrush in her mouth, did she ?\nA Yes.\nQ And she told you to do it ? A. Yes.\nQ Did all the girls do that while you were there ?\nA All of them.\nQ Nobody stopped them ? A.No.\nQ Nobody said to stop ? A.No.\nQ Nobody said anything about it; is that right ?\nA No one said anything about it.\n8 Nobody said it was dangerous to do it ?\nA No; they didn't tell me; they said it wasn't dangerous.\nQ You said ? A. They said it wasn't dangerous.\nQ Who said that ? A.Mr. Savoye.\nQ And he was what; the boss ? A. The boss.\nQ Of that department ?\nA Yes; boss of the whole thing; of the watch dials.\nQ Of the watch dial department ?\nA That is all there was there when I first went there.\nQ Whom did you hear Mr. Savoye say that it wasn't dangerous\nto point it that way ?\nA He told all the girls.\nQ He said it wasn't dangerous to put the brush in the\nmouth ?\n33\nA He said the radium wasn't dangerous.\nQ Did he tell you that ?\nA He told us all that.\nQ You were all there ? A. We were all there.\nQ He didn't tell any particular girl ?\nA They were all there; he told them all the same thing.\nQ How did he come to say that, do you remember at all ?\nHow did he happen to say that ; was there any occasion\nfor it ?\nA Well, I think when we first went there, of course before\nwe had to put the brush in our mouth, the first thing we\nasked, \"Does this stuff hurt you ?\" That would be only\nnatural; and they said no.\nQ Well, the one who said that would be one of the girls\nthat was instructing you probably; is that it ?\nA Yes; then, I suppose, the forelady told Mr. Savoye, and\nMr. Savoye then said that it wasn't, that we didn't need\nto be afraid, because it wasn't.\nQ Well, did he say it to you personally, or did you just\nhappen to be in a group ?\nA When we was all there; all the girls.\nQ All the girls were there ? A. Yes.\nQ Did you hear the forelady say anything to Mr. Savoye,\nor are you just surmising that; you think maybe she did ?\nA I don't know; anyway, he said that it wasn't dangerous.\nQ At any rate, one day you remember distinctly, you say---\nA Yes.\nQ That he did say to the girls, not individually, but al-\ntogether, you mean. A. Yes.\nQ That the radium paint wasn't dangerous.\nA Yes; it wasn't harmful.\nQ But you don't know what made him say that; he just happen-\ned to say it; you don't know the occasion for saying it.\nA I suppose the girls were wondering, working with it and\nputting the brush in their mouth, naturally you don't want\nto put anything in your mouth that is going to hurt you.\nQ Can you remember when that was, when he said that ?\nA No; I don't remember.\nQ Did he say it once, or more than once, that you remember ?\nYou can only speak from your memory, what you remember,\nas to whether he said it once or more than once.\nA Well, I don't remember.\nQ Did you say your sister had worked in the radium plant ?\nA No.\n& Did you have any dentist assist in the removal of the\ntwo teeth that fell out ?\nA No; they fellout themselves.\nQ Didn't need any dentist's assistance ?\nA See this one (indicating) ?\nQ That is loose, too ?\nA That will drop out pretty soon.\nQ How do you feel now; do you have any pains now ?\nA Well, my jaw pains me all the time.\nQ You just pointed to both sides; or one side ?\nA No; on both sides, and down here where Doctor Fields\nsaid there is pus in there, you know.\n35\nQ In the lower jaw ? A.Down here (indicating).\nQ How about the upper jaw ?\nA The upper jaw don't seem to bother me.\nQ You have pain all the time now, or only part of the time ?\nA No; all the time; of course sometimes it is worse than\nothers.\nQ Are those the only pains you have now ?\nA No; I have my back.\nQ Your back pains you ? A. Yes.\n8 All the time, or only occasionally ?\nA Well, it pains a little all the time, not real bad, but\nit gets worse at times that I am in bed.\nQ You are in bed with it ? A.Oh, yes.\nQ For how long ?\nA This whole side becomes paralyzed, too (indicating).\nQ Your right side ? A. Yes.\nQ Any other pains besides that now, at the present time ?\nA No.\n& Your joints don't bother you now ?\nA No; of course this arm has been bad in the last week\n(indicating).\nq hich arm ? A. My right arm.\nOF The whole arm, or just the joint ?\nA The whole arm seems to be, up in the (indicating).\nQ Right through the arm, you mean ?\nA Yes, it aches.\nQ When you try to lift it ?\nA Yes, it hurts when I try to lift it, you know.\n36\na Have you any lack of motion in your arm; that is, can you\nlift it all the way up; is the motion of the arm interfered\nwith at all ?\nA No; I can lift it, but it hurts.\nQYou can put it in the back of your head ?\nA Oh, yes; I can move it around all right.\nQ You haven't any lack of motion; but it hurts ?\nA It hurts when I move it.\nQ You haven't any pains in your knees now, or hips ?\nA Not just now.\na Have you any help in your home, or do you take care of\nthe work yourself ?\nA Well, my sister helps me; when I get down in bed I have\nto get somebody.\nQ I mean when you are not in bed; do you take care of it\nyourself ?\nA Yes; and my niece helps me.\nQ So that ordinarily, when you are not in bed, you do your\nown housework, and take care of your children ?\nA Well, the washing machine does that; I couldn't do it\nany other way.\n& Then when you are in bed, your niece comes in and helps\nyou, or your sister ?\nA And my husband; mostly my husband; it falls on him.\nBY MR. SMITH:\nQ rs.Canfield, what I want to know is this : You say\nwhen you went there Miss Rooney was the forelady. A.Yes.\nQ You say she told Miss Gegenheim to instruct you in what\n37\nto do. A.Yes.\nQ Now, was it to Miss Gegenheim that you said, \"Is this\nstuff dangerous; will it hurt us\" ? Did you say that to Miss\nGegenheim ?\nA I think so, yes; I think we asked her.\nQ No; I mean you; I don't mean anybody else; I mean you.\nA on, yes.\nQ You spoke to Miss Gegenheim about it ?\nA Miss Gegenheim.\nQ And you say she said it NXE wouldn't hurt you ?\nA That is what she said.\nQ You say you heard Mr. Savoye speak about it one time ?\nA Yes.\nQ Can you tell me about when that was ?\nA No; I don't remember when it was.\nQ Had you been in the employ of the company long, or a\nshort time ?\nA No; a short time, I guess.\nQ Just a short time ? A.Just a short time.\nQ The occasion of that was there was a crowd of you girls\ntogether; did he come out and make a speach, or did he say\nit right to you directly, that this thing wouldn't hurt you?\nA No, he didn't say it to me directly; he said it to all the\ngirls on the floor.\nq Where were they, just out on the floor ?\nA We were all sitting in our places.\nQ He came out and spoke to you all at one time ?\nA He came upstairs.\n38\nQ He came upstairs ?\nA Yes; where us girls were.\nQ What did he do; call for silence so that he could talk ?\nA Yes.\nQ And what did he say ?\nA He told us girls that he understood that we were a little\nbit leery about the radium, you know; he said that we didn't\nneed to be, because it was harmless.\nQ You mean the radium paint, or the radium throughout the\nbuilding ?\nA Well, the radium paint.\nQ Did you tell him that you were putting the brush in\nyour mouth ?\nA Well, that is the way we were instructed to do.\nQ I know; but I say, did you tell him that ?\nA Why, he knew that we done it.\nQ I say, did you tell him ? ^.No, I didn't; we were talking\nabout it and naturally thought he knew about it.\nQ That is what Miss Gegenheim told you. A. Yes.\nTaken and sworn to before me :\nthis 17th day of January, 1929:\nHARRY SCHIRMER,\nSupreme Court Examiner.\nSTATE OF NEW JERSEY :\n: SS.\nCOUNTY OF ESSEX :\nRAYMOND CANFIELD, being first duly sworn accord-\ning to law, on his oath deposes and says :\nEXAMINATION BY MR. SMITH :\nQ What is your full name ? A. Raymond Canfield.\nQ Where do you live now ? A. 370 New Street.\nQ How old are you ? A.34.\nQ When were you married ? 4.1917.\nQ The date ? .December 23d.\nQ At the same time and place that Mrs. Canfield has testified\nto ? Yes.\nQ What is your business ? A. Salesman.\nQ For whom ? A. Eureka Vacuum Cleaner Company.\nMR. MARKLEY: Is that in Newark ?\nA I have charge of the Irvington branch.\nQ When did you first notice that Mrs. Canfield was having\nany pains of any kind ?\nA Why, it was just around before Christmas, 1926.\nQ December ? A. Yes; just a short time before Christmas.\nQ Of 1926 ? A. Yes, sir.\nQ What were the first pains that you noticed ; what was the\nevidence that you noticed ?\nA Well, she complained that her jaws hurt her.\nQ Always complained of pains ?\nA At that time she had a very severe attack.\ne What did she first say the attack was ?\nA Well, just like a neuralgia.\nQ Like neuralgia ? A.Yes.\nQ In the face ? A. Yes.\nQ What did you do; anything ?\nA No; she used hot water bags on her jaw.\nQ You didn't call in the doctor ? A No.\nQ How often did that occur ?\nA Well, that was the first time I noticed anything of it.\nQ That was in December, 1926. A.Yes.\nQ When did you next notice any pains ?\nA Well, it was right after the first of the year.\n& About January 1st ?\nA It was right after the 1st; somewhere around January 1st.\nQ What pains were those ? A. The same thing.\nQ What part of the body ?\nA The same thing; well, in the jaws.\nQ Still in the face ? A.Ves.\nMR. MARKLEY: In 1927, you mean ?\nTHE WITNESS: Yes; January, 1927.\nQ What part of the face were they in ?\nA Well, it was on both sides.\nQ Both sides ? A.Yes, sir.\nQ Still no doctor; you didn't send her to any doctor ?\nA No; I thought it was neuralgia.\nQ What did she use ?\nA She used hot water bags; they seemed to give more relief\nthan anything else.\nQ How long did these pains last;at each attach, I mean ?\nA About a week.\nQ They last a whole week ?\nA Sometimes, yes; other times, why, three or four days;\nfour days the shortest.\nQ What you did was to keep on using the hot water bags ?\nA Yes.\n41\nQ Did that keep on right straight from 1926 up to 1928 ?\nA Well, off and on, yes.\nQ About how often would they occur ?\nA Well, that I couldn't hardly say.\ne Well, approximately.\nA Because lots of times she wouldn't say anything to me.\nQ That you know of.\nA Well, I wouldn't like to say, because I couldn't.\nQ You see, you have to give me an estimation, in your mind;\ndid it occur once every two months ?\nA Something like that, yes.\nQ Or once every three months ?\nA Every two or three months that I had noticed.\nQ That is what I mean; what you noticed when you came\nhome at night, you noticed she was in pain.\nA Yes.\nof All these pains were in the face, were they ? A.Yes.\nQ Did you ever see a doctor for that during that time ?\nA Not for that, no.\nQ What ? A.No.\nQ The only thing she used was the hot water bag ?\nA They would seem to give her relief.\n8 The hot water bag would give her relief. A.Yes.\nQ Did these periods or lapses of pain get longer, or short-\ner ? A.It would be longer.\nQ Don't misunderstand me; I mean--- A. You Y mean during\nthe pain.\nQ I mean between pains. Suppose she had the pain this\n42\nweek; then she wouldn't get it, you say, sometimes for,\nwell, a month or two months, or three months. A.Yes.\nQ Now, did this period between pains get longer, or shorter?\nA The pain varied, different times.\nQ What would you say would be the shortest period between\nthose attacks ?\nA Well, I would say this; at the start it was around every\ntwo months, the shortest.\nof Then what did they do, the periods between, grow longer ?\nA No; they didn't seem to grow longer.\nof Well, did they grow shorter ?\nA Well, at times, yes; she might have them two months,\nsometimes three months.\nQ All this time you didn't have her see any doctor at all?\nA Not at the first, no.\nQ When was the first that you saw a doctor about it ?\nA I don't just remember now; I think Doctor Humphreys was\nthe first doctor.\nQ Doctor Humphreys was the first one ? A. Yes.\nQ Hadn't you heard about Doctor Humphreys before you went\nto him ?\nA Never heard of him in my life.\na Never heard of him in your life ?\nA In fact, I didn't know she went to him until she told me.\nQ You hadn't discussed with her or with him about these\nother people working in radium factories ? A. No.\n8 You hadn't discussed the situation at all ? A. No.\n43\nQ of course if you hadn't heard of Doctor Humphreys, you\nweren't the one that sent her to Doc tor Humphreys.\nA No.\nQ Didn't she discuss with you before she went to Doctor\nHumphreys that she was going there ?\nA Yes; she had mentioned his name, because her sister's\nlittle boy was treated by Doctor Humphreys.\n& Her sisterns little boy ? A.Yes; and at the time we\nweren't in very good financial straits, , so she thought\nshe would go there to the clinic and pay a small fee.\n8 What was the matter with the boy ?\nA I don't just remember.\nQ I mean, was it just medical, or was it joint trouble\nand medical ?\nA No; just bones, I think it was; crippled bones.\nQ I mean, did he have some trouble with his bones; the boy?\nA Well, he was bowlegged, I think it was; I think he had\nhis legs straightened.\nQ That is how you came to go to Doctor Humphreys. A. Yes.\nQ You were married in 1917, were you ? A. Yes, sir.\nQ December 23d, 1917 ? A. Yes.\nQ During all that time your wife worked at the Radium\nCompany, did she ? A.Yes. She worked there about a month\nafter we were married.\nQ After you were married. A.Yes.\nQ She left in January, or February ?\nA It was around that time; the last of January or the\nbeginning of February, I think.\n44\nBY MR. MARKLEY:\nQ Have you any statement of what expenses you had ever\nsince you have been to the doctors ?\nA Well, no, not just itemized out.\nQ I understand the first doctor or dentist was Doctor Hodges?\nA Yes.\nQ Do you know what his bill was ?\nA No; I don't; she has taken care of that.\nQ She took care of that . Yes.\nQ Did you pay anything, do you know ?\nA Yes; he was paid.\nof You don't know how much. A.No; I didn't ask her how much.\nQ How about Doctor Jaffe ?\nA I don't know what his bill was.\nQ And Doctor Fields ?\nA $25. is what he charges for X-rays; they are $25.\nQ Doctor Fields charges $25. for X-rays ? A. Yes, sir.\nQ Doctor Humphreys, has he been paid, do you know ?\nA Well, we paid the clinic fees there; I don't remember.\nQ You don't know what they are. A'No.\nQ You are manager, you say, of the Irvington branch of\nthe Eureka Vacuum Cleaner Company. A. Yes, sir.\nQ You said you were also a salesman; you mean a salesman\nin the branch store ?\nA No; I am managing this branch store.\nQ You manage the branch store; you don't go out yourself.\nA No.\n& You just stay there.\nA Yes; I go out, not selling for myself, but training the\nmen; helping them.\nQ You take the men around and show them how to do it.\nA That is it.\nQ Are you on a salary, or commission ? A. Both.\nq Can you give me your average earnings ?\nA Well, it varies anywhere from fifty to seventy-five dollars.\nQ A week ? A. Yes.\nQ You average between fifty and seventy-five dollars.\nA Yes, sir; at the present time.\nQ How long have you been there, Mr.Canfield ?\nA I have been with these people since last June.\nQ June, 1928.\nA Yes; but this just job, I have just been promoted the\nfirst of the year.\nQ You have just been promoted to manager. A.Yes.\nQ Prior to what what were you ? A.Salesman.\nQ Outside salesman ? A.Yes.\nQ You live with your wife and three children, don't you ?\nA Yes.\nQ Anybody else in the family, in your immediate household ?\nA No.\nQ Just you five. A.Yes, sir.\nQ Your wife ordinarily does the housekeeping, except when\nshe is laid up ?\nA She does what she can, yes.\nQ When she is laid up, you help, and her sister helps and\nher niece helps.\n46\nA The oldest boy is quite a help around the house, too.\nQ How old is he now ?\nA Well, he is ten now. She made a mistake.\nof What did she say he was ?\nA I think she said nine.\nQ Are there three boys ? A.No;two boys and a girl.\nTaken and sworn to before me :\nthis 17th day of January, 1929:\nHARRY SCHIRMER,\nSupreme Court Examiner.\nSTATE OF NEW JERSEY :\n: SS.\nCOUNTY OF ESSEX :\nMAE CUBBERLY CANFIELD, being recalled for further\nexamination, on her oath deposes and says :\nEXAMINATION BY MR. SMITH :\nQ Can you tell us about how much you paid Doctor Hodges;\nabout what you paid him ? .Doctor Hodges ?\n8 Yes. A.I paid him for one visit.\nof How much was that ? A.I think $2.\nQ And Doctor Jaffe ? A. Doctor Jaffe, I think, was $1. I\ndon't remember.\nQ And Doctor Fields ? A. Well, Doctor Fields, he charged\nme five dollars, but he usually charges $25; I told him\nI couldn't afford that.\nQ But he charged you five A.Yes.\nQ Have you paid Doctor Humphreys anything ?\nA No, I haven't paid him at all.\nQ Those are the only doctors that you have had ?\n47\nA Yes.\nof The only things that you paid.\nA Yes.\nTaken and sworn to before me :\nthis 17th day of January, 1929:\nHARRY SCHIRMER,\nSupreme Court Examiner.\nI, Harry Schirmer, a Supreme Court Examiner\nof the State of New Jersey, do certify that the fore-\ngoing is a true and accurate transcript of the examin-\nation of the plaintiffs in the above entitled cause,\ntaken by and before me at the time and place herein-\nbefore mentioned; and I believe said transcript fair-\nly and accurately states the testimony given.\nHARRY SCHIRMER,\nSupreme Court Examiner."
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