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UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY HAROLD J. WEBER, Administrator Ad Prosequen- dum of LOUISE HANLE WEBER, deceased, and HAROLD J. WEBER, administrator of the estate of LOUISE HANLE WEBER, deceased, (< Plaintiffs, Action at Law -VS- ( UNITED STATES RADIUM CORPOR- COMPLATIT ATION, a corporation of the ) State of Delaware, Defendant ) The plaintiff Harold J. Weber, administrator ad-pro- sequendum of Louise Hanle Weber, deceased, says that: FIRST COUNT 1. The plaintiff is a resident and eitizen of the municipality of Cave Bridge, Ulster County, in the State of New York. The plaintiff was duly appointed and has qualified as administrator ad pro- sequendum of Louise Hanle Weber, such appointment having been made by the Surrogate of Essex County, New Jersey, on June 17, 1935. 2. The defendant is a corporation of the State of Delaware, 3. The amount in controversy herein exceeds the sum of $3,000.00, exclusive of interest and costs. 4. Prior to, during, and for many years after 1918 the defendant was engaged in the manufacture and sale of various commodities rendered luminous by the application of radio active substances, particularly the dials and hands of watches and clocks. 5. The defendant maintained a plant at Orange, New Jersey where substances containing radio active materials were prepared and applied to the commodities hereinabove mentioned, the radioactive materials used being radium, mesothorium, and thorfum-x. 6. Each of these last mentioned materials whether used alone or in any combination, is inherently potent and inherently highly dangerous and injurious to human health and human tissues when brought into close proximity with the human body or when introduced therein, and was in