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3. While so employed by the defendants, the plaintiff!
intestate was provided by defendants with a small brush which brush
the Plaintiff's intestate was obliged in the doing of her work to
dip in a small crucible in which liquid material had been placed,
the same having been provided by the defendants to the plaintiff's
intestate for that purpose. Before dipping the brush in the
material the plaintiff¹s intestate had been instructed by the
defendants, and the common practice had been ever since the
plaintiff's intestate started to work for the defendants, to
place the brush in the mouth of the worker, and thereupon to dip
the said brush in the crucible containing the materials. That the
liquid material and the brushes furnished by the defendants to
plaintiff's intestate contained certain substances deleterious
to the human body, to the knowledge of the defendants and of which
the plaintiffis intestate had no notice, knowledge or warning, and
the constant use of the same caused such deleterious matter to
enter the system of the plaintiff's intestate; and it is further
alleged that owing to the careless, negligent and improper manner
in which the defendants ordered, permitted and suffered a certain
product, known as radium, or other substance deleterious to the
human body, to be used in and about the plant, fine particles of
the said substance were thrown into the air in close proximity to
where the plaintiff's intestate was working and the plaintiff's
intestate by reason thereof, in breathing carried into her lungs
said particles, causing them to be filled with the said particles
or substance and producing a diseased and injured condition.
4.
As a result of working continously at the work
aforesaid, the particles arising from the use of the radium or
other substance deleterious to human life and limb, in some
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Context sent to Scholar
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"ocrText": "-2-\n3. While so employed by the defendants, the plaintiff!\nintestate was provided by defendants with a small brush which brush\nthe Plaintiff's intestate was obliged in the doing of her work to\ndip in a small crucible in which liquid material had been placed,\nthe same having been provided by the defendants to the plaintiff's\nintestate for that purpose. Before dipping the brush in the\nmaterial the plaintiff¹s intestate had been instructed by the\ndefendants, and the common practice had been ever since the\nplaintiff's intestate started to work for the defendants, to\nplace the brush in the mouth of the worker, and thereupon to dip\nthe said brush in the crucible containing the materials. That the\nliquid material and the brushes furnished by the defendants to\nplaintiff's intestate contained certain substances deleterious\nto the human body, to the knowledge of the defendants and of which\nthe plaintiffis intestate had no notice, knowledge or warning, and\nthe constant use of the same caused such deleterious matter to\nenter the system of the plaintiff's intestate; and it is further\nalleged that owing to the careless, negligent and improper manner\nin which the defendants ordered, permitted and suffered a certain\nproduct, known as radium, or other substance deleterious to the\nhuman body, to be used in and about the plant, fine particles of\nthe said substance were thrown into the air in close proximity to\nwhere the plaintiff's intestate was working and the plaintiff's\nintestate by reason thereof, in breathing carried into her lungs\nsaid particles, causing them to be filled with the said particles\nor substance and producing a diseased and injured condition.\n4.\nAs a result of working continously at the work\naforesaid, the particles arising from the use of the radium or\nother substance deleterious to human life and limb, in some"
}