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UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY.
ANITA J. BURRICELLI,
:
Plaintiff, :
vs.
:
Action at Law.
UNITED STATES RADIUM
:
ANSWER.
CORPORATION, a corporation
of the State of Delaware,
:
Defendant. :
The defendant, a corporation of the State of
Delaware, duly authorized to transact business within the
State of New Jersey, with its principal office at 15 Exchange
Place, Jersey City, New Jersey, says that:
FIRST DEFENSE TO FIRST COUNT.
1. It has no knowledge or information suffi-
cient to form a belief as to paragraph 1.
2. It admits paragraph 2.
3. It denies paragraphs 3 to 13 inclusive.
FIRST DEFENSE TO SECOND COUNT.
1. It repeats its answers to paragraphs 1 to
10 inclusive of the first count.
2. It denies paragraph 2.
3. It repeats its answers to paragraphs 11,
12 and 13 of the first count.
SECOND DEFENSE TO EACH COUNT.
The plaintiff did not suffer any injury or
sustain any loss by reason of any negligence on the part of
the defendant or any of its agents or servants.
THIRD DEFENSE TO EACH COUNT.
The plaintiff did not suffer the injuries or
sustain the losses alleged.
FOURTH DEFENSE TO EACH COUNT.
The plaintiff was guilty of contributory
negligence in failing to exercise that degree of care and
caution for her own safety which was reasonably necessary
under the circumstances.
FIFTH DEFENSE TO EACH COUNT.
The plaintiff, by voluntarily entering into
the employ of the defendant as alleged, under the circumstances
which existed at the time, assumed the risk of any injury which
she might or did suffer.
SIXTH DEFENSE TO EACH COUNT.
The plaintiff assumed the risks of the in-
juries, if any, which she received and therefore cannot recover.
SEVENTH DEFENSE TO EACH COUNT.
The alleged wrongful acts of the defendant
were those of fellow-servants of the plaintiff and therefore
she cannot recover.
EIGHTH DEFENSE TO EACH COUNT.
That any of the injuries alleged to have been
received or sustained by the plaintiff, Anita J. Burricelli,
which said plaintiff did receive or sustain were received and
sustained by said plaintiff at a time when the relation be-
tween her and the defendant was that of employee and employer,
and therefore, any rights and/or remedies which said plaintiff
may have against the defendant were and are embraced by the
terms and provisions of the Workmen's Compensation Act of the
State of New Jersey, and are governed thereby, and therefore,
this court has no jurisdiction over the subject matter of this
suit, and the defendant hereby gives notice that at, upon or
before the trial of this case it will move to dismiss the
complaint on the ground that this court has no jurisdiction.
NINTH DEFENSE TO EACH COUNT.
Each of said alleged causes of action set
forth in the complaint is barred by the Statute of Limitations.
TENTH DEFENSE TO EACH COUNT.
That any and all cause or causes of action
which the plaintiff, Anita J. Burricelli, now has or may have
had against defendant is or are barred by the Statute of Limita-
tions of the State of New Jersey, in that said cause or causes
of action were or are for personal injuries, and were not
brought within two years next after the accrual of said cause
or causes of action, as required by the terms and provisions
of the said Statute of Limitations of the State of New Jersey.
COLLINS & CORBIN,
Attorneys of Defendant.
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY.
ANITA J. BURRICELLI,
Plaintiff,
vs.
UNITED STATES RADIUM
CORPORATION, a corporation
Action at Law.
of the State of Delaware,
Defendant.
ANSWER.
COLLINS & CORBIN,
Attorneys of Defendent,
1 Exchange Place,
Jersey City, N.J.
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"ocrText": "UNITED STATES DISTRICT COURT\nDISTRICT OF NEW JERSEY.\nANITA J. BURRICELLI,\n:\nPlaintiff, :\nvs.\n:\nAction at Law.\nUNITED STATES RADIUM\n:\nANSWER.\nCORPORATION, a corporation\nof the State of Delaware,\n:\nDefendant. :\nThe defendant, a corporation of the State of\nDelaware, duly authorized to transact business within the\nState of New Jersey, with its principal office at 15 Exchange\nPlace, Jersey City, New Jersey, says that:\nFIRST DEFENSE TO FIRST COUNT.\n1. It has no knowledge or information suffi-\ncient to form a belief as to paragraph 1.\n2. It admits paragraph 2.\n3. It denies paragraphs 3 to 13 inclusive.\nFIRST DEFENSE TO SECOND COUNT.\n1. It repeats its answers to paragraphs 1 to\n10 inclusive of the first count.\n2. It denies paragraph 2.\n3. It repeats its answers to paragraphs 11,\n12 and 13 of the first count.\nSECOND DEFENSE TO EACH COUNT.\nThe plaintiff did not suffer any injury or\nsustain any loss by reason of any negligence on the part of\nthe defendant or any of its agents or servants.\nTHIRD DEFENSE TO EACH COUNT.\nThe plaintiff did not suffer the injuries or\nsustain the losses alleged.\nFOURTH DEFENSE TO EACH COUNT.\nThe plaintiff was guilty of contributory\nnegligence in failing to exercise that degree of care and\ncaution for her own safety which was reasonably necessary\nunder the circumstances.\nFIFTH DEFENSE TO EACH COUNT.\nThe plaintiff, by voluntarily entering into\nthe employ of the defendant as alleged, under the circumstances\nwhich existed at the time, assumed the risk of any injury which\nshe might or did suffer.\nSIXTH DEFENSE TO EACH COUNT.\nThe plaintiff assumed the risks of the in-\njuries, if any, which she received and therefore cannot recover.\nSEVENTH DEFENSE TO EACH COUNT.\nThe alleged wrongful acts of the defendant\nwere those of fellow-servants of the plaintiff and therefore\nshe cannot recover.\nEIGHTH DEFENSE TO EACH COUNT.\nThat any of the injuries alleged to have been\nreceived or sustained by the plaintiff, Anita J. Burricelli,\nwhich said plaintiff did receive or sustain were received and\nsustained by said plaintiff at a time when the relation be-\ntween her and the defendant was that of employee and employer,\nand therefore, any rights and/or remedies which said plaintiff\nmay have against the defendant were and are embraced by the\nterms and provisions of the Workmen's Compensation Act of the\nState of New Jersey, and are governed thereby, and therefore,\nthis court has no jurisdiction over the subject matter of this\nsuit, and the defendant hereby gives notice that at, upon or\nbefore the trial of this case it will move to dismiss the\ncomplaint on the ground that this court has no jurisdiction.\nNINTH DEFENSE TO EACH COUNT.\nEach of said alleged causes of action set\nforth in the complaint is barred by the Statute of Limitations.\nTENTH DEFENSE TO EACH COUNT.\nThat any and all cause or causes of action\nwhich the plaintiff, Anita J. Burricelli, now has or may have\nhad against defendant is or are barred by the Statute of Limita-\ntions of the State of New Jersey, in that said cause or causes\nof action were or are for personal injuries, and were not\nbrought within two years next after the accrual of said cause\nor causes of action, as required by the terms and provisions\nof the said Statute of Limitations of the State of New Jersey.\nCOLLINS & CORBIN,\nAttorneys of Defendant.\nUNITED STATES DISTRICT COURT\nDISTRICT OF NEW JERSEY.\nANITA J. BURRICELLI,\nPlaintiff,\nvs.\nUNITED STATES RADIUM\nCORPORATION, a corporation\nAction at Law.\nof the State of Delaware,\nDefendant.\nANSWER.\nCOLLINS & CORBIN,\nAttorneys of Defendent,\n1 Exchange Place,\nJersey City, N.J."
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