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NEW JERSEY SUPREME COURT EXSEX COUNTY. : GRACE FRYER, : Plaintiff, : Action-At-Law vs : COMPLAINT. UNITED STATES RADIUM CORPORATION, a corpora- : tion of the State of Deleware, : Defendant. : Plaintiff, Grace Fryer, residing in the City of Orange, County of Exsex and State of New Jersey complaining says that: FIRST COUNT. 1. From April 1,1917 to January 1,1921, the defendant United States Radium Corporation, was a corporation engaged in the extraction and manufacture of radioactive substances and the manufacture of products of the said radioactive substances for commercial purposes, having its principal place of business at the corner of Alden and High Streets in the City of Orange, County of Essex and State of New Jer- sey. 2. Said radioactive substances which were radium, mesothorium and thorium-x are highly dengerous substances and injurious to the human body when brought into close proximity therewith as those in charge of the defendant's operations well knew. 3. The defendant well knowing the dangerous nature of the said radioactive substances failed to keep the same in control but was negligent in allowing the said dangerous substances to escape and come within close proximity with the plaintiff's person where the said plaintiff was lawfully entitled to be and the said defendant was negli- gent in that it carelessly and negligently placed said substances so that the plaintiff was exposed to the penetrative rays of the said substances, inhaled the dust of the said radioactive substances and the 1