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NEW JERSEY SUPREME COURT
ESSEX COUNTY.
THEODORE KUSER, Administrator
:
ad prosequendum of the Estate
of Hazel Kuser,deceased,
:
Plaintiff,
:
Action at Law
-VS-
:
UNITED STATES RADIUM CORP
:
COMPLAINT.
and ARTHUR ROEDER,
:
Defandants.
:
Plaintiff, Theodore Kuser, Administrator ad prose-
quendum of the Estate of Hazel Kuser, deceased, residing at
153 Watchung Avenue, West Orange, County of Essex and State of
New Jersey, Complaining of the defendants, says that:
1.
The defendant, United States Radium Corp. at
the time hereinafter mentioned was and is now a corporation,
having its principal place of business in the State of New
Jersey, and whose business consists, among other things, of
painting numerals on faces of watches by means of brushes,
in which work certain liquid is provided to the employees as
hereinafter set forth; and defendant, Arthur Roeder, residing
in East Orange, County of Essex and State of New Jersey, and
at the time hereinafter mentioned, was president of the above
mentioned United States Radium Corp. and acted for said corpo-
ration as its general manager, and in full charge of the plant
located as above stated.
2.
For several years and until July,1920, when
she became incapacitated as hereinafter set forth, the plaintiff's
intestate was employed at the plant of the United States Radium
Corp. in and about the work of painting numerals on faces of watches,
with a brush, with a certain liquid provided by the defendants
to the plaintiff's intestate, at its plant in the City of Orange,
County of Essex and State of New Jersey.
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"ocrText": "NEW JERSEY SUPREME COURT\nESSEX COUNTY.\nTHEODORE KUSER, Administrator\n:\nad prosequendum of the Estate\nof Hazel Kuser,deceased,\n:\nPlaintiff,\n:\nAction at Law\n-VS-\n:\nUNITED STATES RADIUM CORP\n:\nCOMPLAINT.\nand ARTHUR ROEDER,\n:\nDefandants.\n:\nPlaintiff, Theodore Kuser, Administrator ad prose-\nquendum of the Estate of Hazel Kuser, deceased, residing at\n153 Watchung Avenue, West Orange, County of Essex and State of\nNew Jersey, Complaining of the defendants, says that:\n1.\nThe defendant, United States Radium Corp. at\nthe time hereinafter mentioned was and is now a corporation,\nhaving its principal place of business in the State of New\nJersey, and whose business consists, among other things, of\npainting numerals on faces of watches by means of brushes,\nin which work certain liquid is provided to the employees as\nhereinafter set forth; and defendant, Arthur Roeder, residing\nin East Orange, County of Essex and State of New Jersey, and\nat the time hereinafter mentioned, was president of the above\nmentioned United States Radium Corp. and acted for said corpo-\nration as its general manager, and in full charge of the plant\nlocated as above stated.\n2.\nFor several years and until July,1920, when\nshe became incapacitated as hereinafter set forth, the plaintiff's\nintestate was employed at the plant of the United States Radium\nCorp. in and about the work of painting numerals on faces of watches,\nwith a brush, with a certain liquid provided by the defendants\nto the plaintiff's intestate, at its plant in the City of Orange,\nCounty of Essex and State of New Jersey."
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