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3. Said radioactive substances referred to in paragraphs 1 and 2
of this complaint which were radium, mesothorium and thorium=x are highly
dangerous substances and injurious to the human body when brought into
close prozimity therewith as those in charge of the defondants' operations
well knew.
4. The defendants, United States Radium Corporation and The Luminite
Corporation, well knowing the dangerous nature of the said radioactive
substances failed to keep the same in control but were negligent in al-
lowing the said dangrous substances to escape and come within close
proximity with the person of the plaintiff, Tdna Hussman where the said
Plaintiff was lamfully entitled to be and the said defendants were
negligent in that they carelessly and negligently placed said substances
so that the plaintiff, Edna Hussman was exposed to the penetrativo rays
of the said substances, inhaled the dust of the said radioactive sub-
stances and the emanations thereof and inzested the same to the great
damage of the said plaintiff, Edna Tlussman.
5. Plaintiff, Edna Hussman was not informed or warned and had no
knowledge of the nature of the said dangerous radioactive substances
into close proximity with which she was by the defendants negligence
brought.
6. Plaintiff, Edna Hussman was exposed to said radioactive substances
for the greater part of the day timé during a period of time from on or
about the first day of June, 1917 to on or about the first day of February
1921, at the plant of the defendant, United States Radium Corporation
hereinbefore referred to in paragraph 1 of this count and from on or
about the first day of February, 1921 to on or about the first day of
September, 1921, at the plant of The Luminite Corporation, referred to
in para/Taph a of this count.
7. By reason of the defendants' negligence as hersinbefore set forth
in paragraph 4 of this count, the body of the plaintiff, Edna Hussman
became impremated with said radioactive substances.
8. Said radioactive substances so introduced into the system of the
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"ocrText": "3. Said radioactive substances referred to in paragraphs 1 and 2\nof this complaint which were radium, mesothorium and thorium=x are highly\ndangerous substances and injurious to the human body when brought into\nclose prozimity therewith as those in charge of the defondants' operations\nwell knew.\n4. The defendants, United States Radium Corporation and The Luminite\nCorporation, well knowing the dangerous nature of the said radioactive\nsubstances failed to keep the same in control but were negligent in al-\nlowing the said dangrous substances to escape and come within close\nproximity with the person of the plaintiff, Tdna Hussman where the said\nPlaintiff was lamfully entitled to be and the said defendants were\nnegligent in that they carelessly and negligently placed said substances\nso that the plaintiff, Edna Hussman was exposed to the penetrativo rays\nof the said substances, inhaled the dust of the said radioactive sub-\nstances and the emanations thereof and inzested the same to the great\ndamage of the said plaintiff, Edna Tlussman.\n5. Plaintiff, Edna Hussman was not informed or warned and had no\nknowledge of the nature of the said dangerous radioactive substances\ninto close proximity with which she was by the defendants negligence\nbrought.\n6. Plaintiff, Edna Hussman was exposed to said radioactive substances\nfor the greater part of the day timé during a period of time from on or\nabout the first day of June, 1917 to on or about the first day of February\n1921, at the plant of the defendant, United States Radium Corporation\nhereinbefore referred to in paragraph 1 of this count and from on or\nabout the first day of February, 1921 to on or about the first day of\nSeptember, 1921, at the plant of The Luminite Corporation, referred to\nin para/Taph a of this count.\n7. By reason of the defendants' negligence as hersinbefore set forth\nin paragraph 4 of this count, the body of the plaintiff, Edna Hussman\nbecame impremated with said radioactive substances.\n8. Said radioactive substances so introduced into the system of the"
}