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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 Essex 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 dangerous 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
4. Plaintiff 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 defendant's negligence brought.
5. Plaintiff was exposed to said radioactive substances for the
greater part of the day time during a period of time from on or about
the 10th day of April 1917 to on or about the first day of January,
1921.
6. By reason of the defendant's negligence as hereinbefore set
forth in paragraph 3 of this count the plaintiff's body became im-
pregnated with said radioactive substances.
7. Said radioactive substances SO introduced into the plaintiff's
system still continue to bombard plaintiff's body internally and cone
tinually attack and break down the plaintiff's tissues and body sub-
stance causing the plaintiff thereby great pain and suffering both
mental and physical.
8. The effect of the introduction of the said radioactive sub-
stances into the human body is such that the effect does not become
immediately apparent and plaintiff did not feel said effect or know
of the beginning of the continuing injury done her until several years
following her last exposure to said dangerous radioactive substances and
the plaintiff was not apprised of the nature of her bodily ailments or
informed or knew that her suffering was due to the negligence of the
defendant until July, 1925.
9. By reason of the premises plaintiff became, was and is sick,
sore, lame and disabled and crippled and has so remained for a long
space of time, becoming ill in June 1922 with continually increasing
pain and suffering both mental and physical from that time unto the
present and during all that time the plaintiff underwent and suffered
and will in the future undergo and suffer reat pain both mental and
physical and plaintiff has been, is and will be hindered and prevented
from transacting her necessary and lawful affairs and has been, is,
oring to be cured of said disability and incapacity received as afore-
said and plaintiff has likewise suffered great loss in that she, be-
cause of her disability and incapacity received as aforesaid will be
unable to pursue a gainful occupation.
Plaintiff demands One Hundred Twenty-Five Thousand ($125000)
Dollars damages in the first count.
SECOND COUNT.
1. Paragraphs 1 and 2 of the first count are hereby repeated as
paragraph 1 of the second count.
2. During the period referred to in paragraph one of this count
plaintiff was employed as a servant of the defendant corporation to
work in defendant's factory in Orange aforesaid.
3. Defendant failed to provide the plaintiff with a safe place to
work but ordered and instructed the plaintiff to handle and to be
constantly in close proximity with quantities of dangerous radioactive
substances.
4. Plaintiff did not know of the dan gerous nature of the said radio-
active substances or their harmful effects upon the human body.
5. Defendant gave no warning to the plaintiff of the dangerous
nature of said radioactive substances into close proximity with which
plaintiff was brought but constantly ordered and directed plaintiff to
be brought into close proximity with said dangerous radioactive sub-
stances with the result that plaintiff was exposed to the penetrative
rays of the said radioactive substances and the emanations thereof and
plaintiff further injested said radioactive substances to the plain-
tiff's great damage.
6. Plaintiff repeats paragraphs 6,7, and 8 of the first count as
paragraph 6 of the second count.
7. As a result of the said introduction of the said dangerous
redioactive substances into the plaintiff's body and defendant's neg-
lect to provide a safe place for plaintiff to work and of defendant's
neglest to warn plaintiff of the dangerous nature of the said radio-
and has suffered, still suffers and will continue to suffer great pain
both mental and physical and has been prevented and will be prevented
from pursuing a gainful occupation and transacting her lawful business
and plaintiff has likewise been compelled and will be in the future
compelled to outlay and expend great sums of money in an endeavor to be
cured of said disability and incapacity received as aforesaid.
Plaintiff demands One Hundred Twenty-five Thousand ($125,000)
Dollars damages on the second count.
(signed) Potter & Berry
Attorneys of Plaintiff
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"ocrText": "NEW JERSEY SUPREME COURT\nEXSEX COUNTY.\n:\nGRACE FRYER,\n:\nPlaintiff,\n:\nAction-At-Law\nvs\n:\nCOMPLAINT.\nUNITED STATES RADIUM\nCORPORATION, a corpora-\n:\ntion of the State of\nDeleware,\n:\nDefendant.\n:\nPlaintiff, Grace Fryer, residing in the City of Orange, County\nof Essex and State of New Jersey complaining says that:\nFIRST COUNT.\n1. From April 1,1917 to January 1,1921, the defendant United\nStates Radium Corporation, was a corporation engaged in the extraction\nand manufacture of radioactive substances and the manufacture of\nproducts of the said radioactive substances for commercial purposes,\nhaving its principal place of business at the corner of Alden and High\nStreets in the City of Orange, County of Essex and State of New Jer-\nsey.\n2. Said radioactive substances which were radium, mesothorium\nand thorium-x are highly dangerous substances and injurious to the\nhuman body when brought into close proximity therewith as those in\ncharge of the defendant's operations well knew.\n3. The defendant well knowing the dangerous nature of the said\nradioactive substances failed to keep the same in control but was\nnegligent in allowing the said dangerous substances to escape and come\nwithin close proximity with the plaintiff's person where the said\nplaintiff was lawfully entitled to be and the said defendant was negli-\ngent in that it carelessly and negligently placed said substances so\nthat the plaintiff was exposed to the penetrative rays of the said\nsubstances, inhaled the dust of the said radioactive substances and the\n4. Plaintiff was not informed or warned and had no knowledge of\nthe nature of the said dangerous radioactive substances into close\nproximity with which she was by the defendant's negligence brought.\n5. Plaintiff was exposed to said radioactive substances for the\ngreater part of the day time during a period of time from on or about\nthe 10th day of April 1917 to on or about the first day of January,\n1921.\n6. By reason of the defendant's negligence as hereinbefore set\nforth in paragraph 3 of this count the plaintiff's body became im-\npregnated with said radioactive substances.\n7. Said radioactive substances SO introduced into the plaintiff's\nsystem still continue to bombard plaintiff's body internally and cone\ntinually attack and break down the plaintiff's tissues and body sub-\nstance causing the plaintiff thereby great pain and suffering both\nmental and physical.\n8. The effect of the introduction of the said radioactive sub-\nstances into the human body is such that the effect does not become\nimmediately apparent and plaintiff did not feel said effect or know\nof the beginning of the continuing injury done her until several years\nfollowing her last exposure to said dangerous radioactive substances and\nthe plaintiff was not apprised of the nature of her bodily ailments or\ninformed or knew that her suffering was due to the negligence of the\ndefendant until July, 1925.\n9. By reason of the premises plaintiff became, was and is sick,\nsore, lame and disabled and crippled and has so remained for a long\nspace of time, becoming ill in June 1922 with continually increasing\npain and suffering both mental and physical from that time unto the\npresent and during all that time the plaintiff underwent and suffered\nand will in the future undergo and suffer reat pain both mental and\nphysical and plaintiff has been, is and will be hindered and prevented\nfrom transacting her necessary and lawful affairs and has been, is,\noring to be cured of said disability and incapacity received as afore-\nsaid and plaintiff has likewise suffered great loss in that she, be-\ncause of her disability and incapacity received as aforesaid will be\nunable to pursue a gainful occupation.\nPlaintiff demands One Hundred Twenty-Five Thousand ($125000)\nDollars damages in the first count.\nSECOND COUNT.\n1. Paragraphs 1 and 2 of the first count are hereby repeated as\nparagraph 1 of the second count.\n2. During the period referred to in paragraph one of this count\nplaintiff was employed as a servant of the defendant corporation to\nwork in defendant's factory in Orange aforesaid.\n3. Defendant failed to provide the plaintiff with a safe place to\nwork but ordered and instructed the plaintiff to handle and to be\nconstantly in close proximity with quantities of dangerous radioactive\nsubstances.\n4. Plaintiff did not know of the dan gerous nature of the said radio-\nactive substances or their harmful effects upon the human body.\n5. Defendant gave no warning to the plaintiff of the dangerous\nnature of said radioactive substances into close proximity with which\nplaintiff was brought but constantly ordered and directed plaintiff to\nbe brought into close proximity with said dangerous radioactive sub-\nstances with the result that plaintiff was exposed to the penetrative\nrays of the said radioactive substances and the emanations thereof and\nplaintiff further injested said radioactive substances to the plain-\ntiff's great damage.\n6. Plaintiff repeats paragraphs 6,7, and 8 of the first count as\nparagraph 6 of the second count.\n7. As a result of the said introduction of the said dangerous\nredioactive substances into the plaintiff's body and defendant's neg-\nlect to provide a safe place for plaintiff to work and of defendant's\nneglest to warn plaintiff of the dangerous nature of the said radio-\nand has suffered, still suffers and will continue to suffer great pain\nboth mental and physical and has been prevented and will be prevented\nfrom pursuing a gainful occupation and transacting her lawful business\nand plaintiff has likewise been compelled and will be in the future\ncompelled to outlay and expend great sums of money in an endeavor to be\ncured of said disability and incapacity received as aforesaid.\nPlaintiff demands One Hundred Twenty-five Thousand ($125,000)\nDollars damages on the second count.\n(signed) Potter & Berry\nAttorneys of Plaintiff"
}