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OCR Page 1 of 9LUCY M. SULLIVAN,
)
UNITED STATES DISTRICT COURT.
Pleintiff,
)
DISTRICT OF NEW JERSEY.
vs
)
UNITED STATES RADIUM
)
CORPORATION, a corporar
tion of the State of
)
ACTION AT LAW.
Delaware,
)
Defendant,
)
The plaintiff, Lucy M, Sullivan, residing at West Orenge,
New Jersey, complaining of the defendant, says that:
1. The plaintiff is a citimen and resident of the Tom of
Nest Orange, County of Essex and State of New Jorsey.
2. The defendant is a corporation of the State of Delaware
and a eitizen thereof.
3. The defendant employed the plaintiff in the year 1917,
in the ordinary course of its business, to work at its plant in Orange, New
Jersey, and she continued to worte for the defendent for a period of about
tio and a holf years painting the luninous dials on timepieces with liquid
compounds consisting in part of one or more of the following substonces,
redium, mesothorium end radium-X, and better known as radium paint.
4. The said defendent, by ita agents and servents, in-
structed the plaintiff in the nannez and nothod of the use of the said con-
pounda and in the manner and use and the handling of brushes for the purpose
of painting the soid compounds on the disls of timepieces. The defendant, by
its agente and servants, instructed the plaintiff and informed hor that the
safe and proper method of shaping the small brushes used to apply the said
liquid compounds was to form or fashion the hair of the said brushes by
curling then in the mouth of the operator and particularly the nouth of the
plaintiff and eurling then around her tongue.
5. It then and there beosmo and was the duty of the said
defendant to use reasonable care to furnish a reasonably safo place for the
plaintiff to work; and to use ressoneble care to furnish reasonably safe and
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