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OCR Page 1 of 8NEW JERSEY SUPREME COURT
ESSEX COUNTY
CATHERINE CONNOLLY and
:
THOMAS CONNOLLY, her husband,
:
Plaintiffs,
:
ACTION AT LAW
vs.
:
COMPLAINT
UNITED STATES RADIUM
CORPORATION (formerly Radium
:
Luminous Material Corp.), a
corporation of the State of
:
Delaware,
:
Defendant.
#
Plaintiffs, Catherine Connolly and Thomas Connolly, her
husband, residing in the City of Newark, County of Essex and State of
New Jersey, complaining of the defendant, say that:
FIRST COUNT
1. At the times hereinafter mentioned, the defendant was en-
gaged in the business, among other things, of manufacturing and distribut-
ing radium and radium products and manufacturing and distributing radium
and other luminous materials.
2. The plaintiff Catherine Connolly was employed by the de-
fendant for a period of time from 1917 to 1924 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 lum-
inous materials into paint and to apply the said paint to the surface of
various cardboard and metal materials, principally used in the manufacture
of watches, clocks and luminous signs.
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