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to 1922 inclusive, in the ardinasy couxse of ite business, to work at the propezation of as substence containing aome or all of the materials abovo sentioned, and in the application thareof to the dials and hands of vatches and clocka and other objecta at the plant mointeined by the defendent in Ogange, New Jersey. 8. ine defendant negligently and carelesaly, and despite its knowlege, actual and constructive, as to the dangerous and iajurious natare of these rediosetive anterials to husen tissua, ao conducted ita business and ao emaed the plainties to oaryy on her work, es to cause hor to ingest and inhale lurge quantities of solid and gescous rediosetive sub- stances contained in end given off from the naterial with which abe worked, and likevise omitted and failed to supply her with ressonsbles adequate and asfe tools, appliances, nethoda and working conditions for garrying on her work, and on the contrary ceused hor to prosecute the sane with unsafe, dangerous and inadequate tools, applianes, nethode and working conditions, and likovise onitted and failed to hor or apprise her of unsual riska attending employment known to ita and to ite knowledge not patent and observable tog and of which, the plaintirs mas wholly ignorant, and likevise omitted and to wazza her or apprise har of the dangerous nature of the rediosative asterials with vhich she was working, end of which ahe uns wholly imorant, and othorwise nogligently und carelessly used and employed the radiosative asterials above nontioned in and about its place of business. 9. As the spoxinate result of the nogligence and caram lessness of the nota and caissions of the defendents atated in the preceding paragrapias sexo thma ingosted and inhaled into the bedy of the plaintirs and bacnse in part, lodged and fixed in varions orgnas and blasues. 10. The natare of the several substances fixed and deposited in the body of the pleintits 1s such thet they contimo to remain potent and active for many years and produce by thoir inherent natural properties de- atructive effects upon banan bones, tissues and other portions of the body, of which properties and actions the defendent $03, in 1917, charged with knowledge. 11, The fact of the injurious setion and effect of redio-

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0
Type
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Document data

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75728926
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Type
document
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Page context
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    "ocrText": "to 1922 inclusive, in the ardinasy couxse of ite business, to work at the\npropezation of as substence containing aome or all of the materials\nabovo sentioned, and in the application thareof to the dials and hands\nof vatches and clocka and other objecta at the plant mointeined by the\ndefendent in Ogange, New Jersey.\n8.\nine defendant negligently and carelesaly, and despite\nits knowlege, actual and constructive, as to the dangerous and iajurious\nnatare of these rediosetive anterials to husen tissua, ao conducted ita\nbusiness and ao emaed the plainties to oaryy on her work, es to cause hor\nto ingest and inhale lurge quantities of solid and gescous rediosetive sub-\nstances contained in end given off from the naterial with which abe worked,\nand likevise omitted and failed to supply her with ressonsbles adequate\nand asfe tools, appliances, nethoda and working conditions for garrying on\nher work, and on the contrary ceused hor to prosecute the sane with unsafe,\ndangerous and inadequate tools, applianes, nethode and working conditions,\nand likovise onitted and failed to hor or apprise her of unsual riska\nattending employment known to ita and to ite knowledge not patent and\nobservable tog and of which, the plaintirs mas wholly ignorant, and likevise\nomitted and to wazza her or apprise har of the dangerous nature of the\nrediosative asterials with vhich she was working, end of which ahe uns wholly\nimorant, and othorwise nogligently und carelessly used and employed the\nradiosative asterials above nontioned in and about its place of business.\n9.\nAs the spoxinate result of the nogligence and caram\nlessness of the nota and caissions of the defendents atated in the preceding\nparagrapias sexo thma ingosted and inhaled into the bedy\nof the plaintirs and bacnse in part, lodged and fixed in varions orgnas and\nblasues.\n10. The natare of the several substances fixed and deposited\nin the body of the pleintits 1s such thet they contimo to remain potent and\nactive for many years and produce by thoir inherent natural properties de-\natructive effects upon banan bones, tissues and other portions of the body,\nof which properties and actions the defendent $03, in 1917, charged with\nknowledge.\n11, The fact of the injurious setion and effect of redio-"
}