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fact highly dangerous and injurious as used by the defendant in the quantities
employed in carrying on the operations hereinabove mentioned.
7.
The defendant employed the decedent in the year 1918
and for about two years thereafter, in the ordinary course of its business,
to work at the preparation of a substance containing some or all of the
radio active materials above mentioned, and in the actual application thereof
to the dials and hands of watches and clocks, at the plant maintained by the
defendant in Orange, New Jersey.
8.
The defendant negligently and carelessly, and despite
its knowledge, actual and constructive, as to the dangerous and injurious
nature of these radioactive materials to human tissues, so conducted its
business and 80 caused the decedent to carry on her work, as to cause her to
ingest and inhale large quantities of solid and gaseous redicactive sub-
stances contained in and given off from the material with which she worked,
and likewise omitted and failed to supply her with reasonably adequate and
safe tools, appliances, methods and working conditions for carrying on her
work, and on the contrary caused her to prosecute the same with unsafe,
dangerous and inadequate tools, appliances, methods and working conditions, and
likewise omitted and failed to warn her or apprise her of umisual risks attend-
ing her employment known to it and to its knowledge not patent and observable
to the decedent and of which the decedent was wholly ignorant,and likewise
omitted and failed to warn her or apprise her of the dangerous nature of the
radioactive materials with which she was working, and of which she was wholly
ignorant, and otherwise negligently and carelessly used and employed the
redioactive materials above mentioned in and about its place of business.
9.
As the proximate result of the negligence and careless-
ness of the acts and omissions of the defendant stated in the preceding para-
graph, radioactive materials were thus ingested and inhaled into the body of
the decedent and became in pert, lodged and fixed in various organs and tissues,
10. The nature of the several substances fixed and deposited
in the body of the plaintiffis decedent is such that they continue to remain
potent and active for many years and produce by their inherent natural
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Document data
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DTO data
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Context sent to Scholar
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"ocrText": "fact highly dangerous and injurious as used by the defendant in the quantities\nemployed in carrying on the operations hereinabove mentioned.\n7.\nThe defendant employed the decedent in the year 1918\nand for about two years thereafter, in the ordinary course of its business,\nto work at the preparation of a substance containing some or all of the\nradio active materials above mentioned, and in the actual application thereof\nto the dials and hands of watches and clocks, at the plant maintained by the\ndefendant in Orange, New Jersey.\n8.\nThe defendant negligently and carelessly, and despite\nits knowledge, actual and constructive, as to the dangerous and injurious\nnature of these radioactive materials to human tissues, so conducted its\nbusiness and 80 caused the decedent to carry on her work, as to cause her to\ningest and inhale large quantities of solid and gaseous redicactive sub-\nstances contained in and given off from the material with which she worked,\nand likewise omitted and failed to supply her with reasonably adequate and\nsafe tools, appliances, methods and working conditions for carrying on her\nwork, and on the contrary caused her to prosecute the same with unsafe,\ndangerous and inadequate tools, appliances, methods and working conditions, and\nlikewise omitted and failed to warn her or apprise her of umisual risks attend-\ning her employment known to it and to its knowledge not patent and observable\nto the decedent and of which the decedent was wholly ignorant,and likewise\nomitted and failed to warn her or apprise her of the dangerous nature of the\nradioactive materials with which she was working, and of which she was wholly\nignorant, and otherwise negligently and carelessly used and employed the\nredioactive materials above mentioned in and about its place of business.\n9.\nAs the proximate result of the negligence and careless-\nness of the acts and omissions of the defendant stated in the preceding para-\ngraph, radioactive materials were thus ingested and inhaled into the body of\nthe decedent and became in pert, lodged and fixed in various organs and tissues,\n10. The nature of the several substances fixed and deposited\nin the body of the plaintiffis decedent is such that they continue to remain\npotent and active for many years and produce by their inherent natural"
}