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{
    "localId": "75730573",
    "label": "Telegram to H.H. Barker, December 26, year unknown",
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    "citationUrl": "https://catalog.archives.gov/id/75730573"
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{
    "id": "75730573",
    "sourceUrl": "https://catalog.archives.gov/id/75730573",
    "contentType": "document",
    "title": "Telegram to H.H. Barker, December 26, year unknown",
    "citationUrl": "https://catalog.archives.gov/id/75730573",
    "collections": [
        "Safety Light Collection",
        "Records Related to Radium Dial Painters"
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{
    "seq": 7,
    "pageIndex": 0,
    "type": "document",
    "url": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0003654.pdf",
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    "ocrText": "NEW JERSEY SUPREME COURT\nESSRX COUNTY.\nEDNA HUSSMAN and LOUIS\n:\nHUSSMAN,\n:\nPlaintiffs,\n:\nAction-At-Law\nVS\n:\nCOMPLAINT.\nUNITED STATES RADIUM CORPORA-\n:\nTION, a corporation of the State\nof Delaware, individually, end\n:\nTHE LUMINITE CORPORATION, a corp-\noration of the State of Now Jer-\n:\nsey, individually, and UNITED\nSTATES RADIUM CORPORATION, a corp-\n:\noration of the State of Delaware\nand THE LUMINITE CORPORATION, a\n#\ncorporation of the State of New\nJersey, jointly, and UNITED STATES\n:\nRADIUM CORPORATION, B corporation\nof the State of Delaware and in the\n:\nalternative, THE LUMINITE CORPORATION,\na corporation of the State of New\n:\nJersey,\n:\nDefendants.\nPlaintiffs, Edna Hussman and Louis Hussman, residing in the Tom\nof Bloomfield, County of Essex and State of New Jersey complaining say\nthat:\nFIRST COUNT.\n1. From on or about the first day of June, 1917 to on or about\nFebruary 1, 1921, the defendant United States Redium Corporation was a\ncorporation engaged in the extraction and manufacture of radionctive\nsubstances and the manufacture of products of the said radioactive sub-\nstances for commercial purposes, having its principal place of business\nat the corner of Alden and High Streets in the City of Orange, County of\nEssex and State of New Jersey.\n2. From on or about Fe truary 1,1921 to on or about September 1,\n1921, the defendant, The Luminite Corporation, was a corporation engaged\nin the handling of redioactive substances and the manufacture of products\nof said radioactive substances for commercial purposes, having its\nprincipal place of business at Bos. 24-30 Scott Street, in the City of\nNewark, County of Esez and State 02 you\n3. Said radioactive substances referred to in paragraphs 1 and\nof this complaint which were radium, mosotherium and thorium-x are highly\ndangerous substances and injurious to the human body when brought into\nclose proximity therewith as those in charge of the defendants' operations\nwell know.\n4. The defendants, United States Radium Corporation and The Luminito\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 and dangerous substances to escape and come within close\nproximity with the person of the plaintiff, Edna Hussman where the said\nPlaintiff was lawfully entitled to be and the said defendants were\nnegligent in that they carolessly and negligently placed said substances\n80 that the plaintiff, Edna Hussman was exposed to the penetrative rays\nof the said substances, inhaled the dust of the said radioactive sub-\nstances and the omenations thereof and ingested the same to the great\ndanage of the said plaintiff, Edna Hussman.\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, Edas Hussman was exposed to mid radioactive substances\nfor the greater part of the day time 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\nhereinbofore referred to in peragraph 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 paragraph 2 of this count.\n7. By reason of the defendants' neclicence as hereinbefore set forth\nin paragraph 4 of this count, the body of the plaintiff, Dina R ssman\nbecame impremated with said radioactive substances.\nplaintiff, Edna Hussman still continue to bombard said plaintiff's body\ninternally and continually attack and break down the said plaintiff's\ntissues and body substance causing the said plaintiff, Edna Russean great\npain and suffering both mental and physical.\n9. The effect of the introduction of the said radioactive substances\ninto the human body is such that the effect does not become immediately\napparent and plaintiff, Edna Hussman did not fool said effect or know\nof the beginning of the continuing injury done her until several years\nfollowing her last exposure to said dangerous redionctive substances and\nthe plaintiff, Edna Hussman was not apprased of the nature of her bodily\nailments or informed or know that her suffering was due to the negligence\nof the defendents until on or about the first day of May, 1927.\n10. By reason of the premises plaintiff, Edan Hussman become, was and\nis sick, sore, lame, disabled and crippled with continually increasing\npain and suffering both mental and physical from the time of the commonce-\nment of her illness unto the present, during all of which time the\nplaintiff, Edna Hussman underwent and suffored and will in the future\nundergo and suffer great pain both mental and physical and plaintiff,\nEdna Hussman has been, is and will be hindered and prevented from trans-\nacting her lawful affairs and has been is and will be deprived of divers\nlarge gains and money spent in endeavoring to be cured of said disability\nand incapacity received as aforessid and plaintiff, Edna Huseman has\nlikewise suffered great loss in that she because of her disability and\nincapacity received as aforessid, has been unable and will be unable to\npursue a gainful occupation.\nPlaintiff, Edna Hussman domands against the defendant, United States\nRadium Corporation, individually, and against The Luminito Corporation,\nindividually, and or against the United States Radium Corporation and The\nLuminite Corporation jointly and or against the United States Redium\nCorporation or in the alternative against the defendent The Luminite\nCorporation, One Hundred and Twenty-five Thousand ($125,000) Dollars\ndamages on the first count.\nSECOND COUNT.\n1. Paragraphs 1,2 and 3 of the first count are hereby repeated as\nparagraph 1 of the second count.\n2. During the period from on or about the first day of June,1917 to\non or about the first day of February, 1921, plaintiff, Edna Hussman was\nemployed as a servant of the defendant, United States Redium Corporation\nto work in said defendant's factory, in Orange, aforesaid, and from on or\na tout the first day of February, 1921 to on or about the first day of\nSeptember,1921, the plaintiff, Edna Huseman was employed as a servant of\nthe defendant The Luminite Corporation to work in said defendent's factory\nin Newark, aforesaid.\n3. Said defendant, United States Radium Corporation fáiled to provide\nthe plaintiff, Edna Hussman with a safe place to work but ordered and in-\nstructed said plaintiff, Edna Hussman to handle and to be constantly in\nclose proximity with quantities of dangerous radionctive substances.\n4. Said defendent, The Luminite Corporation failed to provide the\nPlaintiff, Edna Ruseman with a safe place to work but ordered and instruct\ned the plaintiff, Edna Hussman to handle and to be constantly in close\nproximity with quantities of dangerous radioactive substances.\n5. Plaintiff, Edna Hussman did not know of the dangerous nature of\nthe said radioactive substances or their harmful effects upon the human\nbody.\n6. Defendant, United States Radium Corporation gave no warning to\nthe plaintiff, Edna Hussman of the dangerous nature of said redionctive\nsubstances into close proximity with which plaintiff, Bina Hussman was\nbrought but constantly ordered and directed said plaintiff, Illns Russman\nto be brought into close proximity with said dangerous radioactive sub-\nstances with the result that plaintiff, Edna Hussman was exposed to the\npenetrative rays of the said radioactive substances and the emanations\nthereof and plaintiff, Edne Hussmen further ingested said radioactive\ntiff, Edna Bussnon of the dangerous nature of said radionctive succtsness\ninto close proximity with which said plaintiff, Edna Bussman was brought\nbut constantly ordered and directed said plaintiff, Edna Hussnan to be\nbrought into close proximity with said dongerous radioactive substances\nwith the result that the plaintiff, Edne was exposed to the\npenetrative roys of 0:14 radioactive substances and the emanations thereof\nand said plaintiff Edna Russean ingested said radioactive substances to\nthe great drmage of the g:1d plaintiff, Sina Hussmon.\n8. Plaintiff, Sins Hunsman repeats paragraph 7,8 and 9 of the first\ncount as paragraph 8 of the second count.\n9. As 8 result of the said introduction of the said dangerous radio-\nactive substances into the body of the plaintiff, Edna Hussnen and the\nDefendents' neglect to warn plaintiff, Edna Bussman of the dangerous\nnature of the said dengerous redioactive substances, plaintiff, Edna\nRussman has become sick, sore, lame and disabled and has suffered, still\nsuffers and will continue to suffer great pain both mental and physical\nand has been prevented and will be prevented from transacting her lawful\nbusiness and has been compelled and will be compelled to outlay and\nexpend great sume of money in an endenvor to be cured of said disability\nand incapacity received as aforesaid.\nPlaintiff, Edna Russman, demands against the defendent, United States\nRadium Corporation, individually, and against the Luminite Corporation,\nindividually, and or against the United States Radium Corporation and\nThe Luminite Corporation jointly and or against the United States Radium\nCorporation or in the alternativo against the defendant The Luminite\nCorporation, One Hundred and Twenty-five Thousand ($125,000) Dollars\ndamages on the second count.\nSHIRD COUNT.\n1. Plaintiff, Louis Russman repeats the allegations contained in\nparagraphs 1 to 10 inclusive of the first count and paragraphs 1 to 9\ninclusive of the second count as paragraph 1 of the third count.\n2. Plaintiff, Edna Husanan,mentioned in the first and second counts\nof this complaint is the wife of the plaintiff, Louis Hussman.\n3. By reason of the defendants' negligence as set out in the first\nand second counts of this complaint the said Edna Hussmon sustained the\ninjuried as set out in the first and second counts and in consequence of\nsaid injuries the plaintiff, Louis Hussman lost the services of his\nsaid wife and in the future will be deprived of the services of his said\nwife and has in the past and will in the future be deprived of the con-\nfort and aid of her socity and has been and in the future will be com-\npelled to lay out and expend large sumo of money for doctor bills and\nmedicines in an endeavor to treat and cure his said wife of her injuries.\nPlaintiff, Louis Hussman demands against the defendant, United States\nRadium Corporation, individually, and against the Luminite Corporation,\nindividually, and or against the United States Radium Corporation and\nThe Luminite Corporation jointly and or against the United States Radium\nCorporation or in the alternative against the defendent The Luminite\nCorporation, Twenty-five Thousand ($25,000) Dollars damages on the third\ncount.\n(signed) Pottor & Borry\nAttorneys of Plaintiffs."
}