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NEW JERSEY SUPREME COURT ESSEX COUNTY FRANCES TAPPEN HOARE and JAMES HOARE, her husband, : Plaintiffs, : vs. UNITED STATES RADIUM : CORPORATION (formerly Radium ACTION AT LAW Luminous Material Corporation) : COMPLAINT a corporation of the State of Delaware, : Defendant. : : Plaintiffs, Frances Tappen Hoare and James Hoare, her husband, residing in the City of Orange, County of Essex and State of New Jersey say that: FIRST COUNT 1. At the times hereinafter mentioned the defendant was engaged in the business, among other things, of manufacturing and distributing radium and radium products, and manufacturing and distributing radium and other lumin- ous materials. 2. The plaintiff Frances Tappen Hoare was employed by the defen- dant during part of the year 1916 and part of the year 1917 at its plants in the Cities of Newark and Orange, New Jersey. 3. At the time and place aforesaid, the said plaintiff was directed by the agents and servants of the defendant to mix certain luminous materials into paint and to apply the said paint to the surfaces of various cardboard and metal materials, principally used in the manufacture of watches, clock and luminous signs. 4. The materials used in making said luminous paint and the implements employed in mixing and applying said paint were furnished by the defendant and the plaintiff was instructed in the manner in which said materials were to be mixed and the said paint applied by the agents and servants of the defentant. 5. The defendant knew or should have known that the materials furnished to the plaintiff in the performance of her duties as aforesaid contain- ed substances which were dangerous, poisonous and deleterious to the body and health of the plaintiff, and knew or should have known that the method and manner

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0
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Document data

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75725262
Core
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Type
document
DTO data
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Context sent to Scholar

Document identity
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Document source metadata
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Page context
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    "ocrText": "NEW JERSEY SUPREME COURT\nESSEX COUNTY\nFRANCES TAPPEN HOARE and\nJAMES HOARE, her husband,\n:\nPlaintiffs,\n:\nvs.\nUNITED STATES RADIUM\n:\nCORPORATION (formerly Radium\nACTION AT LAW\nLuminous Material Corporation)\n:\nCOMPLAINT\na corporation of the State of\nDelaware,\n:\nDefendant.\n:\n:\nPlaintiffs, Frances Tappen Hoare and James Hoare, her husband,\nresiding in the City of Orange, County of Essex and State of New Jersey say that:\nFIRST COUNT\n1. At the times hereinafter mentioned the defendant was engaged\nin the business, among other things, of manufacturing and distributing radium\nand radium products, and manufacturing and distributing radium and other lumin-\nous materials.\n2. The plaintiff Frances Tappen Hoare was employed by the defen-\ndant during part of the year 1916 and part of the year 1917 at its plants in the\nCities of Newark and Orange, New Jersey.\n3. At the time and place aforesaid, the said plaintiff was\ndirected by the agents and servants of the defendant to mix certain luminous\nmaterials into paint and to apply the said paint to the surfaces of various\ncardboard and metal materials, principally used in the manufacture of watches,\nclock and luminous signs.\n4. The materials used in making said luminous paint and the\nimplements employed in mixing and applying said paint were furnished by the\ndefendant and the plaintiff was instructed in the manner in which said materials\nwere to be mixed and the said paint applied by the agents and servants of the\ndefentant.\n5. The defendant knew or should have known that the materials\nfurnished to the plaintiff in the performance of her duties as aforesaid contain-\ned substances which were dangerous, poisonous and deleterious to the body and\nhealth of the plaintiff, and knew or should have known that the method and manner"
}