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{
    "localId": "75721814",
    "label": "Copies of Court Documents, August , 1927",
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    "dtoType": "document",
    "citationUrl": "https://catalog.archives.gov/id/75721814"
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{
    "id": "75721814",
    "sourceUrl": "https://catalog.archives.gov/id/75721814",
    "contentType": "document",
    "title": "Copies of Court Documents, August , 1927",
    "citationUrl": "https://catalog.archives.gov/id/75721814",
    "collections": [
        "Safety Light Collection",
        "Records Related to Radium Dial Painters"
    ],
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    "source": "import",
    "hasTranscription": false
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{
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{
    "seq": 9,
    "pageIndex": 0,
    "type": "document",
    "url": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001055.pdf",
    "mediaId": "b3de4e341a0055f1",
    "ocrText": "IN CHANCERY OF NEW JERSEY.\nBetween\nGRACE FRYER,\n:\nComplainant,\n:\n:\n-and-\nOn Bill.\n:\nUNITED STATES RADIUM CORPORA-\n:\nANSWER.\nTION, a corporation of the\nState of Delaware,\n:\nDefendant.\n:\nThe answer of the defendant, United States\nRadium Corporation, a corporation of the State of Delaware,\nduly authorized to transact business in the State of New Jer-\nsey, with its principal office in the latter state, in the\nCity of Jersey City, County of Hudson and State of New Jer-\nsey, says that:\n1. Answering Paragraph 1 of the complaint\nherein, it admits that the complainant was employed by the\ndefendant from November 8, 1918 to on or about March 19, 1920,\nbut it has no knowledge or information sufficient to form a\nbelief as to whether the complainant was employed by it at any\nother time; it admits that complainant's employment consisted\nin mixing a powder which defendant corporation supplied to com-\nplainant, with glue and water, with which complainant was like-\nwise supplied by the defendant, into a paste of the proper\nconsistency, which paste complainant then applied with a small\ncamel hair brush to numerals on the dials of watches; it ad-\nmits that said operation required some skill in the use of the\nbrush with which it was necessary to mark a fine line; it de-\nnies that in order to secure a fine point with which to draw\nthe necessary fine line with the brush, complaiment was in-\nstructed by defendant to point said brush by putting the same\nin her mouth; it has no knowledge or information sufficient\nto form a belief as to whether complainant used to point said\nbrush by putting the same in her mouth, and it denies that it\nwas customary for complainant's 00-workers to 80 point the\nbrush; it has no knowledge or information sufficient to form\na belief as to whether the brush, if 02\" when pointed by the\nlips, contained emall quantities of said paste hereinbefore\nreferred to, or whether some of said paste would remain on\ncomplainant's lips and was eventually swallowed by her. It\ndenies that said powder hereinbefore referred to, which was\nmixed into the paste, was very light and that the air in the\nworkroom was saturated with said powder, and it denies that\ncomplainant breathed said powder and that said powder adhered\nto all parts of her body and elothing, and it has no knowledge\nor information sufficient to form a belief that upon returning\nhome, complainant's olothing and parts of her body would be\nluminous in the dark; it denies the remaining allegations\nof Paragraph 1.\n2. Answering Paragraph 2, defendant has\nno knowledge or information sufficient to form a belief as\nto whether complainant had no knowledge whatsoever as to the\ningredients which she mixed together to form the said paste;\nit has no knowledge or information sufficient to form a be-\nlief as to whether the complainant knew that the application\nwhich she made to the dials of watches was for the purpose\nof rendering the numerals, on said dials, luminous in the\ndark; likewise, it has no knowledge or information suffi-\neient to form a belief as to whether the complainant, from\nthe name of the defendant corporation, drew the inference\nthat an ingredient of the substance she applied, was radium;\nit denies that radium is commonly known to have the character-\nistics of luminosity in the dark; it denies that the infini-\ntesimal amount of radium contained in the said paste or paint\nor mixture, was dangerous; it has no knowledge or information\nsufficient to form a belief as to what skill or knowledge of\nphysics or chemistry complainant had, and it has no knowledge\nor information sufficient to form a belief as to how well in-\nformed the complainant was with respect to the contents of\nsaid mixture; it denies the remaining allegations of Para-\ngraph 2.\n3. Answering Paragraph 3, the defendant de-\nnies the first sentence of said paragraph, but admits that at\ntimes said mixture or paint used by the complainant contained\ninfinitesimal portions of radium, mesothorium or thorium X;\nit denies that said infinitesimal portions of said radium,\nmesothorium or thorium X, as used in said paint or mixture,\nwere highly dangerous and destructive to bodily tiesues when\nbrought into close proximity therewith, and it further denies\nthat the defendant or its agents or servants in charge of its\noperation, knew that said infinitesimal portions aforessid of\nsaid radium, mesothorium or thorium X, were highly dangerous\nand destructive as aforessid; it denies the remaining allege-\ntions of Paragraph 3.\n4. Answering Paragraph 4, defendant denies\nthat it well knew that the infinitecimal portions of said\nradium, mesothorium or thorium X contained in said paint or\nmixture were exceedingly harmful to bodily tissues when\nbrought into close proximity therewith; it admits it gave\nthe complainant no warning of any such alleged harmful con-\ndition of said paint or mixture; it denies that it constant-\nly instructed and required complainant to be in close proxim-\nity with said radioactive substances, and it denies that the\ncomplainant was exposed to the rays of said radioactive sub-\nstances and the emanations thereof, except that it admits\nthat the complainant came in contact with the paint or mix-\nture aforesaid containing an infinitesimal amount or quantity\nof radium, mesothorium or thorium X; it denies that the com-\nplainant ingested radioactive substances to her great damage,\nas a result of which complainant, through the period set forth\nin Paragraph 1 of the said bill of complaint, constantly ab-\nsorbed quantities of radioactive substances until her body\nbecame impregnated throughout with such radioactive substances;\nit denies the remaining allegations of Paragraph 4, except that\nit admits that complainant was not instructed or warned of the\nalleged dangerous nature of said paint or mixture, and it fur-\nther denies that said paint or mixture was of a dangerous\nnature.\n5. It has no knowledge or information sufficient\nto form a belief as to the allegations of Paragraph 5.\n6. It denies Paragraph 6, except that it ad-\nmits that complainant was finally successful in instituting\nsuit.\n7. It admits Paragraph 7.\n8. Answering Paragraph 8, it denies that the\ndefendant corporation, prior to and during the period referred\nto in Paragraph 1 of the bill of complaint herein, knew that\nthe infinitesimal quantities of radioactive substances used\nin said paint or mixture, were of a dangerous and lethal\nnature, and it further denies that said paint or mixture was,\nin fact, of a dangerous and lethal nature, and it denies that\nthe complainant was exposed to dangerous substances when she\nwas exposed to said paint or mixture; it denies the remaining\nallegations of Paragraph 8 except that upon information and\nbelief it alleges that an alleged autopsy was performed by the\ncounty physician on two deceased persons who were formerly\nemployees of the defendant, and except further that it admits\na report of an alleged investigation was published in The\nJournal of the American Medical Association in December 1925.\n9. Further answering the bill, this defendant\nsays that the complainant 1s in gross laches; that the complain-\nant claimed to know that her alleged illness or illnesses were\ndue to said alleged paint and the radioactive substances alleged\nto be contained therein long before the bill of complaint herein\nwas filed, and for the purpose of bringing an action against this\ndefendant the complainant employed counsel other than the com-\nplainant's present counsel of record long prior to the filing\nof a bill herein.\n10. Further answering the bill, defendant says\nthat upon the face of the bill it appears that there 10 no\nequity in the bill.\nCOLLINS & CORBIN\nSolicitors for and of counsel\nwith the Defendant.\nIN CHANGERY OF NEW JERSEY\nBetween\nGRACE FRYER,\n:\nComplainant,\n:\nOn Bill, &\n-and-\n$ ANSWERS TO INTERROGATORIES\nANNEXED TO THE BILL OF COM-\nUNITED STATES RADIUM CORPORA- :\nPLAINT HEREIN.\nTION, a corporation of the\nState of Delaware,\n:\nDefendant.\n:\nTo - Mesers. Potter & Berry,\nSelicitors of Complainent.\nSIRS:\nThe following are answers to the interrogatories\nannexed to the bill of complaint herein; each answer beare\nthe number of the interrogatory to which it is a reply:-\n1. Defendant employed Dr. Cecil K. Drinker\nbut not his colleagues.\n2. Defendant paid Dr. Drinker but not his 001-\nleagues.\n3. No.\n4. Defendant requested Dr. Frederick B. Flinn\nto make investigation of effect, if any, on human system of\nluminous paint manufactured and used by defendant.\n5. Prior to Dr. Drinker's investigation steps\nwere $ aken to investigate the condition of health of employees\nof defendant.\n6. Yes.\nDATED: August 30, 1927.\nRespectfully yours,\nCOLLINS & CORBIN\nSolicitors of Defendant\nSTATE OF NEW JERSEY :\n: 88.\nCOUNTY OF HUDSON\n:\n0. B. IBE, being duly sworn according to law\non his oath, deposes and says:\nI an President of the United States Radium Cor-\nporation. I have read the interrogatories annexed to the\nbill of complaint in the above entitled action and the fore-\ngoing answers thereto, and said answers are true to the best\nof my knowledge, information and belief.\nSnorn and subscribed to at :\nJersey City, N. J., this\n:\nday of August, 1927,\n:\nbefore me,\n:\nIN CHANCERY OF NEW JERSEY\nBetween\nGRACE FRYER,\nComplainant,\nOn Bill, &0,\n-and-\nUNITED STATES RADIUM COR-\nPORAT ION, a corporation of\nthe State of Delaware,\nDefendant.\nANSWER TO BILL OF COMPLAINT AND\nANSWERS TO INTERROGATORIES AN-\nNEXED TO BILL OF COMPLAINT.\nCOLLINS & CORBIN,\nSol're of Defendant,\n1 Exchange Place,\nJersey City, N.J."
}