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UNITED STATES DISTRICT COURT. District of New Jersey. ETHELWYNNE METZ, et al, : : Plaintiffs, : : VS. : AT Law. : UNITED STATES RADIUM COR- : PORATION, a corporation, : : Defendant. : Plaintiffs' Memorandum on Statute of Limitations. This action was commenced December 15, 1928, in a state court of New Jersey and was removed to this court, at defendant's instance, for diversity of citizen- ship. The complaint contains two counts in behalf of plaintiff ETHELWYNNE METZ and one count in behalf of her husband, plaintiff EDWARD METZ. By the first count, plaintiff ETHELWYNNE METZ demands $200,000 damages, because of defendant's negligence in causing and requiring her, while in its employ, to be subjected to the deleterious effects of certain danger- ous and poisonous substances, defined as radium or as thorium-x. By the second count, plaintiff ETHELWYNNE METZ