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UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERGEY
HAROLD J. WEBER, Administrator
:
Ad Prosequendum of LOUISE HANLE
WEBER, deceased, and HAROLD J.
:
WEBER, administrator of the
estate of LOUISE HANLE WEBER,
:
deceased,
Plaintiffs, :
Action at Law.
VS.
: DEMAND FOR PARTICULARS
UNITED STATES RADIUM CORPORATION,
a corporation of the State of
:
Delaware,
Defendant. :
TO - EMMERGLICK & EMERGLICK, ESQS.,
and HARRY T. SHERMAN, ESQ.,
Attorneys for and of Counsel with Plaintiffs.
SIRS:
The defendent demands particulars of the causes of
action of the plaintiffs in the following respects:
1. What is the full name, age and address of the
plaintiff? What was the age of the deceased when she died?
2. What was the name of the deceased at the time she
worked for the defendant?
3. On what date did the deceased begin her employment
with the defendant and how long did it continue?
4. Was said employment uninterrupted? If not, please
state during what period said plaintiff was unemployed.
5. State in detail the nature of the work which the
deceased plaintiff did for the defendant.
6. If the position of the deceased was changed during
her employment by the defendent, state the difference in the
nature of the work after the change or changes, giving the
dates of changes.
7. What was the name or names of the superior or
superiors of the deceased when she entered the defendant's
employ and during her continuance therein?
8. In what department or departments of the
business of the defendant did the deceased work, giving the
date of employment in each department?
9. State in detail the nature of the work that the
deceased did during her entire employment.
10. Who, giving the names, instructed the deceased
in her duties in each department in which she worked?
11. On what date did the deceased last apply
luminous paint to objects while in defendent's employ? How
was said paint applied and how we the brush pointed? If the
brush was pointed with the lips, state in detail how said work
was done, and state each person who gave instructions for the
pointing of the brush with the lips.
12. when did the deceased leave the employ of the
defendent and what employment has said deceased been engaged
in since she left the employ of the defendant, the names and
addresses of the employers and the nature of the work done at
each employment.
13. On what date did the deceased first feel the
symptoms of her alleged illness complained of in the complaint?
14. Describe with as great detail as practicable the
first symptoms and how they changed, if they did, and what said
symptoms were at the time of death. What parts of the body
did they affect?
15. State the date and place of the marriage of the
deceased and by whom the marriage was performed.
16. State what issue there is of said marriage,
giving the names and ages of the children.
17. Give the names and addresses of the physicians,
surgeons, dentists and other medical men who have treated the
deceased during the past ten years.
18. Give the names and addresses of any hospitals or
institutions in which the deceased may have been confined
during the past ten years.
19. Give an itemized statement of the out of pocket
moneys disbursed by the deceased and the plaintiff as a
result of said alleged illnesses referred to in the complaint.
20. Give an itemized statement of all bills incurred
for medicines or medical aid.
21. State in detail all dental work which may have
been done on the mouth of the deceased during the past ten
years and the names and addresses of the dentists who per-
formed same.
22. State in detail all illnesses or diseases from
which the deceased has suffered during the past ten years
and what treatment or treatments she has had for same and the
names and addresses of the physicians who have given such
treatments or medical aid.
23. When did the deceased and the plaintiff first
know that radium was part of the paint which the deceased
applied to various articles?
DATED: July 24, 1935.
COLLINS & COR BIN.
Attorneys of Defendent.
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
HAROLD J. WEBER, Adminis-
trator Ad Prosequendum of
LOUISE HANLE WEBER, deceased,
and HAROLD J. WEBER, adminis-
trator of the estate of LOUISE
HANLE WEBER, deceased,
Plaintiffs,
VS.
UNITED STATES RAD IUM COR-
PORATION, a corporation of
Action at Law
the State of Delaware,
Defendant.
DEMAND FOR PARTICULARS
COLLINS & CORBIN,
Attorneys of Defendant,
1 Exchange Place,
Jersey City, N. J.
Service of a copy of the
within Demand for Particulars
acknowledged this
day
of
1935.
Attorneys for and of Counsel
with Plaintiffs.
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"ocrText": "UNITED STATES DISTRICT COURT\nDISTRICT OF NEW JERGEY\nHAROLD J. WEBER, Administrator\n:\nAd Prosequendum of LOUISE HANLE\nWEBER, deceased, and HAROLD J.\n:\nWEBER, administrator of the\nestate of LOUISE HANLE WEBER,\n:\ndeceased,\nPlaintiffs, :\nAction at Law.\nVS.\n: DEMAND FOR PARTICULARS\nUNITED STATES RADIUM CORPORATION,\na corporation of the State of\n:\nDelaware,\nDefendant. :\nTO - EMMERGLICK & EMERGLICK, ESQS.,\nand HARRY T. SHERMAN, ESQ.,\nAttorneys for and of Counsel with Plaintiffs.\nSIRS:\nThe defendent demands particulars of the causes of\naction of the plaintiffs in the following respects:\n1. What is the full name, age and address of the\nplaintiff? What was the age of the deceased when she died?\n2. What was the name of the deceased at the time she\nworked for the defendant?\n3. On what date did the deceased begin her employment\nwith the defendant and how long did it continue?\n4. Was said employment uninterrupted? If not, please\nstate during what period said plaintiff was unemployed.\n5. State in detail the nature of the work which the\ndeceased plaintiff did for the defendant.\n6. If the position of the deceased was changed during\nher employment by the defendent, state the difference in the\nnature of the work after the change or changes, giving the\ndates of changes.\n7. What was the name or names of the superior or\nsuperiors of the deceased when she entered the defendant's\nemploy and during her continuance therein?\n8. In what department or departments of the\nbusiness of the defendant did the deceased work, giving the\ndate of employment in each department?\n9. State in detail the nature of the work that the\ndeceased did during her entire employment.\n10. Who, giving the names, instructed the deceased\nin her duties in each department in which she worked?\n11. On what date did the deceased last apply\nluminous paint to objects while in defendent's employ? How\nwas said paint applied and how we the brush pointed? If the\nbrush was pointed with the lips, state in detail how said work\nwas done, and state each person who gave instructions for the\npointing of the brush with the lips.\n12. when did the deceased leave the employ of the\ndefendent and what employment has said deceased been engaged\nin since she left the employ of the defendant, the names and\naddresses of the employers and the nature of the work done at\neach employment.\n13. On what date did the deceased first feel the\nsymptoms of her alleged illness complained of in the complaint?\n14. Describe with as great detail as practicable the\nfirst symptoms and how they changed, if they did, and what said\nsymptoms were at the time of death. What parts of the body\ndid they affect?\n15. State the date and place of the marriage of the\ndeceased and by whom the marriage was performed.\n16. State what issue there is of said marriage,\ngiving the names and ages of the children.\n17. Give the names and addresses of the physicians,\nsurgeons, dentists and other medical men who have treated the\ndeceased during the past ten years.\n18. Give the names and addresses of any hospitals or\ninstitutions in which the deceased may have been confined\nduring the past ten years.\n19. Give an itemized statement of the out of pocket\nmoneys disbursed by the deceased and the plaintiff as a\nresult of said alleged illnesses referred to in the complaint.\n20. Give an itemized statement of all bills incurred\nfor medicines or medical aid.\n21. State in detail all dental work which may have\nbeen done on the mouth of the deceased during the past ten\nyears and the names and addresses of the dentists who per-\nformed same.\n22. State in detail all illnesses or diseases from\nwhich the deceased has suffered during the past ten years\nand what treatment or treatments she has had for same and the\nnames and addresses of the physicians who have given such\ntreatments or medical aid.\n23. When did the deceased and the plaintiff first\nknow that radium was part of the paint which the deceased\napplied to various articles?\nDATED: July 24, 1935.\nCOLLINS & COR BIN.\nAttorneys of Defendent.\nUNITED STATES DISTRICT COURT\nDISTRICT OF NEW JERSEY\nHAROLD J. WEBER, Adminis-\ntrator Ad Prosequendum of\nLOUISE HANLE WEBER, deceased,\nand HAROLD J. WEBER, adminis-\ntrator of the estate of LOUISE\nHANLE WEBER, deceased,\nPlaintiffs,\nVS.\nUNITED STATES RAD IUM COR-\nPORATION, a corporation of\nAction at Law\nthe State of Delaware,\nDefendant.\nDEMAND FOR PARTICULARS\nCOLLINS & CORBIN,\nAttorneys of Defendant,\n1 Exchange Place,\nJersey City, N. J.\nService of a copy of the\nwithin Demand for Particulars\nacknowledged this\nday\nof\n1935.\nAttorneys for and of Counsel\nwith Plaintiffs."
}