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UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY.
ANITA J. BURRICELLI,
:
Plaintiff,
:
ACTION AT LAW
vs.
:
UNITED STATES RADIUM
:
BILL OF PARTICULARS.
CORPORATION, a corporation
of the State of Delaware,
:
Defendant.
:
1. Thirty-three years old. See complaint.
2. The employment commenced about a week after
the plant at Alden and High Streets, Orange, opened in 1917.
3. Plant at Alden and High Streets, Orange, N.J.
4. At the present time the only information the
plaintiff has is that the employment terminated in or about
the year 1922.
5. Continuous.
6. The plaintiff began to work for the defendant
after leaving school.
7. After a short interval, the plaintiff began
to work as a clerk in Muir's Department Store, East Orange,
New Jersey, which continued for about five years.
8. Not married.
9. The plaintiff painted dials on Yankee watches
almost exclusively, working only for a short time on
Waterbury dials and compasses.
10. No change except as stated in 9.
11. Mr. Savoy, Miss Rooney, Miss Smith, Miss
Rollins, Miss Cubberly and Mrs. Russell.
12. See 9.
13. The plaintiff mixed luminous paint contained
in a small vial with an adhesive and a thinner and applied
it to the figures on watch dials with a fine camels hair
brush.
14. The persons mentioned in number 11 with the
exception of Mr. Savoy.
15. See 4.
16. The paint was applied by dipping the brush
into the container of paint and painting one or more figures,
and thereafter the brush was dipped into a crucible of water
to loosen the hardened paint and then it was pointed in the
mouth before re-dipping it in the paint.
17. The brush was pointed in the mouth by the use
of the lips and tongue and this was done in accordance with
instructions from the persons referred to in paragraph 14.
18. Improper.
19. Improper.
20. The medical bills paid or incurred are as
follows:-- $561.00; $20.00; $100.00; $35.00; $40.00; $30.00;
$40.00; $30,00; $3.00; $15.00; $25.00; $148.00; $16.00;
$5.00; $5.00; $9.00; $15.00; $10.00; $25.00; $6.00 and $20.00.
21. Dental bills paid or incurred are as follows: --
$5.00 x-ray; $150.00 extraction and treatment; $100.00 dental
plate.
22. Hospital bills paid or incurred are as follows:
$49.50; $83.25; $42.00; $89.25; $165.60; $14.00; $78;60;
$7.00; $28.00; $7.00; $14.00; $7.00; $10.00; $5.50; $35.00;
$42.00; $55.00 and $65.50. Several other items the exact
amounts of which are not presently available.
23. Approximately $168.00 for nursing, and a sum
not presently available for medicines and medical supplies.
24. See above. In addition to the items herein-
above mentioned, some bills were paid and the records are
not available at the present time.
25. All upper and six lower teeth were extracted
and followed with treatment.
26. In 1917 after her employment began.
27. The weekly wage varied and was as high as
$52.00 per week at times. The plaintiff was paid $.84 a tray
for painting Yankee dials.
28. Unemployed.
29. The plaintiff suffered pain in her hands, arms,
hips, legs, head and ears. She suffered pain in her teeth
prior to and during extraction and in her jaws following ex-
traction. The plaintiff underwent three head operations be-
cause of the condition of the bones of her head and the
destruction thereof by radioactive substances deposited there-
in, which caused her much pain, annoyance, inconvenience and
lasting injury and pain. Plaintiff suffered discharges from
her ears which were attended with pain. The foregoing were
the result of the deposit in her bones and other organs of
radioactive substances taken into her system during the course
of her employment and by reason of the misconduct of the de-
fendant as charged in the complainant.
30. The plaintiff does not know the exact dates
of all the periods when she was confined to her bed. On
some days she would suffer pain which would not be severe
enough to cause her to take to her bed, and others that it
would be necessary for her to remain in bed. The plaintiff
is unable to specify any dates except the following:
May 29th, 1933, head operation. Two weeks in
hospital and period at home unknown at the present time.
April 16th, 1934, head operation. Two weeks in
hospital and a period at home thereafter, unknown at the
present time.
May 7th, 1935, head operation 24 days in hospital
and period at home thereafter, unknown at the present time.
31. Plaintiff suffers intense pain in her head,
ears, legs at the present time which has continued from a
period beginning several months before her operation on
May 29th, 1933, except that the pain in the legs is
spasmodic.
MILTON M. UNGER.
ATTORNEY FOR PLAINTIFF.
EL.
8/19/35.
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY.
ANITA J. BURRICELLI,
Plaintiff,
vs.
UNITED STATES RADIUM
CORPORATION, a corporation
of the State of Delaware,
Defendant.
day of August, 1935.
ATTORNEYS FOR DEFENDANT.
COLLINS & CORBIN
is hereby acknowledged this 20th
SERVICE of the within Bill of Particulars
ACTION AT LAW
BILL OF PARTICULARS.
MILTON M. UNGER
11 Commerce Street
Newark, N.J.
Attorney for Plaintiff.
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"ocrText": "UNITED STATES DISTRICT COURT\nDISTRICT OF NEW JERSEY.\nANITA J. BURRICELLI,\n:\nPlaintiff,\n:\nACTION AT LAW\nvs.\n:\nUNITED STATES RADIUM\n:\nBILL OF PARTICULARS.\nCORPORATION, a corporation\nof the State of Delaware,\n:\nDefendant.\n:\n1. Thirty-three years old. See complaint.\n2. The employment commenced about a week after\nthe plant at Alden and High Streets, Orange, opened in 1917.\n3. Plant at Alden and High Streets, Orange, N.J.\n4. At the present time the only information the\nplaintiff has is that the employment terminated in or about\nthe year 1922.\n5. Continuous.\n6. The plaintiff began to work for the defendant\nafter leaving school.\n7. After a short interval, the plaintiff began\nto work as a clerk in Muir's Department Store, East Orange,\nNew Jersey, which continued for about five years.\n8. Not married.\n9. The plaintiff painted dials on Yankee watches\nalmost exclusively, working only for a short time on\nWaterbury dials and compasses.\n10. No change except as stated in 9.\n11. Mr. Savoy, Miss Rooney, Miss Smith, Miss\nRollins, Miss Cubberly and Mrs. Russell.\n12. See 9.\n13. The plaintiff mixed luminous paint contained\nin a small vial with an adhesive and a thinner and applied\nit to the figures on watch dials with a fine camels hair\nbrush.\n14. The persons mentioned in number 11 with the\nexception of Mr. Savoy.\n15. See 4.\n16. The paint was applied by dipping the brush\ninto the container of paint and painting one or more figures,\nand thereafter the brush was dipped into a crucible of water\nto loosen the hardened paint and then it was pointed in the\nmouth before re-dipping it in the paint.\n17. The brush was pointed in the mouth by the use\nof the lips and tongue and this was done in accordance with\ninstructions from the persons referred to in paragraph 14.\n18. Improper.\n19. Improper.\n20. The medical bills paid or incurred are as\nfollows:-- $561.00; $20.00; $100.00; $35.00; $40.00; $30.00;\n$40.00; $30,00; $3.00; $15.00; $25.00; $148.00; $16.00;\n$5.00; $5.00; $9.00; $15.00; $10.00; $25.00; $6.00 and $20.00.\n21. Dental bills paid or incurred are as follows: --\n$5.00 x-ray; $150.00 extraction and treatment; $100.00 dental\nplate.\n22. Hospital bills paid or incurred are as follows:\n$49.50; $83.25; $42.00; $89.25; $165.60; $14.00; $78;60;\n$7.00; $28.00; $7.00; $14.00; $7.00; $10.00; $5.50; $35.00;\n$42.00; $55.00 and $65.50. Several other items the exact\namounts of which are not presently available.\n23. Approximately $168.00 for nursing, and a sum\nnot presently available for medicines and medical supplies.\n24. See above. In addition to the items herein-\nabove mentioned, some bills were paid and the records are\nnot available at the present time.\n25. All upper and six lower teeth were extracted\nand followed with treatment.\n26. In 1917 after her employment began.\n27. The weekly wage varied and was as high as\n$52.00 per week at times. The plaintiff was paid $.84 a tray\nfor painting Yankee dials.\n28. Unemployed.\n29. The plaintiff suffered pain in her hands, arms,\nhips, legs, head and ears. She suffered pain in her teeth\nprior to and during extraction and in her jaws following ex-\ntraction. The plaintiff underwent three head operations be-\ncause of the condition of the bones of her head and the\ndestruction thereof by radioactive substances deposited there-\nin, which caused her much pain, annoyance, inconvenience and\nlasting injury and pain. Plaintiff suffered discharges from\nher ears which were attended with pain. The foregoing were\nthe result of the deposit in her bones and other organs of\nradioactive substances taken into her system during the course\nof her employment and by reason of the misconduct of the de-\nfendant as charged in the complainant.\n30. The plaintiff does not know the exact dates\nof all the periods when she was confined to her bed. On\nsome days she would suffer pain which would not be severe\nenough to cause her to take to her bed, and others that it\nwould be necessary for her to remain in bed. The plaintiff\nis unable to specify any dates except the following:\nMay 29th, 1933, head operation. Two weeks in\nhospital and period at home unknown at the present time.\nApril 16th, 1934, head operation. Two weeks in\nhospital and a period at home thereafter, unknown at the\npresent time.\nMay 7th, 1935, head operation 24 days in hospital\nand period at home thereafter, unknown at the present time.\n31. Plaintiff suffers intense pain in her head,\nears, legs at the present time which has continued from a\nperiod beginning several months before her operation on\nMay 29th, 1933, except that the pain in the legs is\nspasmodic.\nMILTON M. UNGER.\nATTORNEY FOR PLAINTIFF.\nEL.\n8/19/35.\nUNITED STATES DISTRICT COURT\nDISTRICT OF NEW JERSEY.\nANITA J. BURRICELLI,\nPlaintiff,\nvs.\nUNITED STATES RADIUM\nCORPORATION, a corporation\nof the State of Delaware,\nDefendant.\nday of August, 1935.\nATTORNEYS FOR DEFENDANT.\nCOLLINS & CORBIN\nis hereby acknowledged this 20th\nSERVICE of the within Bill of Particulars\nACTION AT LAW\nBILL OF PARTICULARS.\nMILTON M. UNGER\n11 Commerce Street\nNewark, N.J.\nAttorney for Plaintiff."
}