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OCR Page 1 of 711470
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY.
ANITA J. BURRICELLI,
:
Plaintiff, :
-VS-
:
IN UTTY
UNITED STATES RADIUM
:
CORPORATION, a corporation
of the State of Delaware,
:
COMPLAINT.
Defendant, *
de
The plaintiff, ANITA J. BURRICELLI, residing at 34 Tompkins Street,
West Orange, New Jersey, says that:--
FIRST COUNT.
1.
The plaintiff is a resident and citizen of the Municipality of
West Orange, Essey County, New Jersey.
2.
The defendant is a corporation of the State of Delaware.
3. The amount in controversy herein exceeds the sum of $3,000 ex-
clusive of interest and costs.
4.
Prior to and during the year 1917, the defendant was engaged in
the manufacture and sale of various commodities and particularly in the pro-
duction of luminous dials for watches and clocks.
5.
The defendant maintained a plant or factory in the Municipality
of Orange, New Jersey, where it carried on the work aforesaid and where it em-
ployed persons to render luminous dials of time pieces by the application
of radio active substances.
6.
The plaintiff herein heretofore instituted suit in this court at
law against the defendant for damages resulting from the conduct of the
defendant toward the plaintiff, Anita J. Burricelli, while the latter was em-
ployed by the defendant to paint the dials of time pieces as aforesaid. A
copy of the complaint is annexed hereto, made part hereof and marked Schedule A.
7.
The defendant filed an answer to the complaint setting up, in
several separate defenses, that the respective causes of action of the plain-
tiff are barred by the statute of limitations of the State of New Jersey
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