Ask the Scholar
Page 5 of 5
I can add historical knowledge about this page.
Page image
OCR
NEW JERSEY SUP REME COURT
ESSEX COUNTY
GRACE LOHNEFINKE,
Plaintiff,
vs.
UNITED STATES RADIUM COR-
Action at Law.
PORATION, a corporation of
the State of Delaware,
Defendant.
PETITION FOR REMOVAL OF CAUSE
COLLINS & CORBIN,
Attorneys of Defendant,
1 Exchange Place,
Jersey City, N. J.
NEW JERSEY SUPREME COURT
ESSEX COUNTY
GRACE LOHNEFINKE,
:
Plaintiff,
:
vs.
:
Action at Law.
UNITED STATES RAD IUM COR-
: PETITION FOR REMOVAL OF
PORATION, a corporation
CAUSE.
of the State of Delaware,
:
Defendant.
:
TO THE HONORABLE JUSTICES OF THE NEW JERSEY SUPREME COURT:
The petition of United States Radium Corporation,
a corporation of the State of Delaware, in the above entitled
cause, urespectfully shows that:
1. The plaintiff above named is the only plain-
tiff in the above entitled suit, and was at the time of the
commencement of said suit and still is a resident of the Town
of Bloomfield, County of Essex, State of New Jersey, and a
citizen of the said state or a citizen of some foreign state
or country.
2. Your petitioner is the only defendant in
said suit and was at the time of the commencement of said suit
and still is a corporation organized and existing under and by
virtue of the laws of the State of Delaware and a resident and
citizen of said State of Delaware.
3. Said suit is of a civil nature, at law, and
the matter in controversy exceeds, exclusive of interest and
costs, the sum or value of $3000.
4. The controversy in said suit is wholly be-
tween citizens of different states.
5. No special bail was originally or is re-
quisite in said suit.
6. Said suit was commenced by the service of
a summons and complaint upon the defendant on February 3,
1933, by serving a copy thereof on the Corporation Trust Com-
pany, 15 Exchange Place, Jersey City, N. J. as registered
agent, and the time within which the defendant is required to
answer said complaint has not expired but will expire on
February 23, 1933 unless further time to answer is allowed.
The defendant has not filed its answer to said complaint or in
any way appeared therein.
7. Your petitioner has made and filed herein a
bond with good and sufficient surety for its entering in the
District Court of the United States for the District of New
Jersey, within thirty days from the filing of this petition,
a certified copy of the record in said suit, and for paying
all costs that may be awarded by said District Court if said
District Court shall hold that said suit was wrongfully or
improperly removed thereto, said bond being in the penal sum
of $500., conditioned as required by the Act of Congress in
such case made and provided.
Your petitioner prays this Honorable Court to
proceed no further in said suit except to accept this petition
and bond, make the order of removal required by law and cause
the record in said suit to be removed into said District Court
of the United States for the District of New Jersey, pursuant
to the Act of Congress in such case made and provided.
And your petitioner will ever pray, etc.
UNITED STATES RADIUM CORPORATION,
By
President.
COLLINS & CORBIN.
Attorneys of Petitioner.
STATE OF NEW YORK :
: SS.
COUNTY OF NEW YORK:
, of full age, being
duly sworn according to law, on his oath, says that he is
President of UNITED STATES RADIUM CORPORATION, the
defendant in the within mentioned suit and the petitioner
named in the foregoing petition; that he has read said pe-
tition and knows the contents thereof and that the matters
stated therein are true; that the matter in controversy exceeds,
exclusive of interest and costs, the sum or value of $3000.
that said suit is of a civil nature, at law, in the New Jersey
Supreme Court, Essex County, and is between citizens of
different states, as appears from the complaint of the
plaintiff herein, and he is informed and believes that the
District Court of the United States has original jurisdiction
thereof; and that the controversy in said suit can be fully
determined as between the plaintiff and the defendent.
Subscribed and sworn to
:
at New York, N. Y. this
day of February,
:
1933, before me, a
:
duly commissioned and sworn,
as witness my hand and of-
:
ficial seal.
:
Page data
- Page
- 5
- Source index
- 0
- Type
- document
- Media ID
- 63f20896191cc9c4
- Size
- unknown
Document data
- ID
- 75727444
- Core
- doc
- Type
- document
DTO data
{
"id": "75727444",
"sourceUrl": "https://catalog.archives.gov/id/75727444",
"contentType": "document",
"title": "Deposition, February , 1933",
"citationUrl": "https://catalog.archives.gov/id/75727444",
"collections": [
"Safety Light Collection",
"Records Related to Radium Dial Painters"
],
"iiifBase": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0002758_Page_1.jpg",
"thumbnailUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0002758_Page_1.jpg",
"largeImageUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0002758_Page_1.jpg",
"imageCount": 5,
"hasImages": true,
"source": "import",
"hasTranscription": false
}
Context sent to Scholar
Document identity
{
"localId": "75727444",
"label": "Deposition, February , 1933",
"core": "doc",
"dtoType": "document",
"citationUrl": "https://catalog.archives.gov/id/75727444"
}
Document source metadata
{
"id": "75727444",
"sourceUrl": "https://catalog.archives.gov/id/75727444",
"contentType": "document",
"title": "Deposition, February , 1933",
"citationUrl": "https://catalog.archives.gov/id/75727444",
"collections": [
"Safety Light Collection",
"Records Related to Radium Dial Painters"
],
"iiifBase": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0002758_Page_1.jpg",
"thumbnailUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0002758_Page_1.jpg",
"largeImageUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0002758_Page_1.jpg",
"imageCount": 5,
"hasImages": true,
"source": "import",
"hasTranscription": false
}
Document source extras
{
"url": "https://catalog.archives.gov/id/75727444",
"naId": 75727444,
"levelOfDescription": "fileUnit",
"recordType": "description",
"ocrSource": "nara-archive"
}
Page context
{
"seq": 5,
"pageIndex": 0,
"type": "document",
"url": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0002758.pdf",
"mediaId": "63f20896191cc9c4",
"ocrText": "NEW JERSEY SUP REME COURT\nESSEX COUNTY\nGRACE LOHNEFINKE,\nPlaintiff,\nvs.\nUNITED STATES RADIUM COR-\nAction at Law.\nPORATION, a corporation of\nthe State of Delaware,\nDefendant.\nPETITION FOR REMOVAL OF CAUSE\nCOLLINS & CORBIN,\nAttorneys of Defendant,\n1 Exchange Place,\nJersey City, N. J.\nNEW JERSEY SUPREME COURT\nESSEX COUNTY\nGRACE LOHNEFINKE,\n:\nPlaintiff,\n:\nvs.\n:\nAction at Law.\nUNITED STATES RAD IUM COR-\n: PETITION FOR REMOVAL OF\nPORATION, a corporation\nCAUSE.\nof the State of Delaware,\n:\nDefendant.\n:\nTO THE HONORABLE JUSTICES OF THE NEW JERSEY SUPREME COURT:\nThe petition of United States Radium Corporation,\na corporation of the State of Delaware, in the above entitled\ncause, urespectfully shows that:\n1. The plaintiff above named is the only plain-\ntiff in the above entitled suit, and was at the time of the\ncommencement of said suit and still is a resident of the Town\nof Bloomfield, County of Essex, State of New Jersey, and a\ncitizen of the said state or a citizen of some foreign state\nor country.\n2. Your petitioner is the only defendant in\nsaid suit and was at the time of the commencement of said suit\nand still is a corporation organized and existing under and by\nvirtue of the laws of the State of Delaware and a resident and\ncitizen of said State of Delaware.\n3. Said suit is of a civil nature, at law, and\nthe matter in controversy exceeds, exclusive of interest and\ncosts, the sum or value of $3000.\n4. The controversy in said suit is wholly be-\ntween citizens of different states.\n5. No special bail was originally or is re-\nquisite in said suit.\n6. Said suit was commenced by the service of\na summons and complaint upon the defendant on February 3,\n1933, by serving a copy thereof on the Corporation Trust Com-\npany, 15 Exchange Place, Jersey City, N. J. as registered\nagent, and the time within which the defendant is required to\nanswer said complaint has not expired but will expire on\nFebruary 23, 1933 unless further time to answer is allowed.\nThe defendant has not filed its answer to said complaint or in\nany way appeared therein.\n7. Your petitioner has made and filed herein a\nbond with good and sufficient surety for its entering in the\nDistrict Court of the United States for the District of New\nJersey, within thirty days from the filing of this petition,\na certified copy of the record in said suit, and for paying\nall costs that may be awarded by said District Court if said\nDistrict Court shall hold that said suit was wrongfully or\nimproperly removed thereto, said bond being in the penal sum\nof $500., conditioned as required by the Act of Congress in\nsuch case made and provided.\nYour petitioner prays this Honorable Court to\nproceed no further in said suit except to accept this petition\nand bond, make the order of removal required by law and cause\nthe record in said suit to be removed into said District Court\nof the United States for the District of New Jersey, pursuant\nto the Act of Congress in such case made and provided.\nAnd your petitioner will ever pray, etc.\nUNITED STATES RADIUM CORPORATION,\nBy\nPresident.\nCOLLINS & CORBIN.\nAttorneys of Petitioner.\nSTATE OF NEW YORK :\n: SS.\nCOUNTY OF NEW YORK:\n, of full age, being\nduly sworn according to law, on his oath, says that he is\nPresident of UNITED STATES RADIUM CORPORATION, the\ndefendant in the within mentioned suit and the petitioner\nnamed in the foregoing petition; that he has read said pe-\ntition and knows the contents thereof and that the matters\nstated therein are true; that the matter in controversy exceeds,\nexclusive of interest and costs, the sum or value of $3000.\nthat said suit is of a civil nature, at law, in the New Jersey\nSupreme Court, Essex County, and is between citizens of\ndifferent states, as appears from the complaint of the\nplaintiff herein, and he is informed and believes that the\nDistrict Court of the United States has original jurisdiction\nthereof; and that the controversy in said suit can be fully\ndetermined as between the plaintiff and the defendent.\nSubscribed and sworn to\n:\nat New York, N. Y. this\nday of February,\n:\n1933, before me, a\n:\nduly commissioned and sworn,\nas witness my hand and of-\n:\nficial seal.\n:"
}