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OCR Page 1 of 9UNITED STATES DISTRICT COURT.
District of New Jersey.
ETHELWYNNE METZ, et al,
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Plaintiffs,
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VS.
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AT Law.
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UNITED STATES RADIUM COR-
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PORATION, a corporation,
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Defendant.
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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
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