Ask the Scholar
Page 7 of 7
I can add historical knowledge about this page.
Page image
OCR
IN CHANGERY OF NEW JERSEY
Between
#
KATHERINE SCHAUB,
:
Complainant, :
and
:
On Bill, to.
UNITED STATES RADIUM COR-
#
PORATION, as corporation of
the State of Delaware,
:
Defendant.
:
:
The answer of the defendant, United States
Radium Corporation, a corporation of the State of Delaware,
duly authorized to transact business in the State of New Jer-
sey, with its principal office in the latter State in the
City of Jersey City, County of Hudson and State of New Jersey,
says that:
1. Answering Paragraph 1 of the complaint here-
in, while it admits that the complainant was employed by it
during a certain period of time, it denies that the complainant
was employed by the defendent from on or about the first day
of February, 1917, to on or about the first day of July, 1920,
and from on or about the 27th day of November, 1920, to on or
about the seventh day of June, 1921; it admits that complain-
ant's employment consisted in mixing a powder which defendant
corporation supplied to complainant, with glue and water, with
which complainent was likewise supplied by the defendent, into
a paste of the proper consistency, which paste complainant the
applied with a small camel hair brush to numerals on the dials
or watches; it admits that said operation required some skill
in the use of the brush with which it was necessary to mark
a fine line; it denies that in order to secure a fine point
with which to draw the necessary fine line with the brush,
complainant was instructed by defendant to point said brush
by putting the same in her mouth; it has no knowledge or in-
formation sufficient to form a belief as to whether complain-
ant used to point said brush by putting the same in her mouth,
and it denies that it was customery for complainant's co-wrkers
to so point the brush; it has no knowledge or information suffi-
cient to form a belief as to whether the brush, if or when
pointed by the lips, contained small quantities of said paste
hereinbefore referred to, or whether some of said paste would
remain on complainant's lips and was evan tually swallowed by
her. It denies that said powder hereinbefore referred to,
which was mixed into the paste, was very light and that the
air in the workroom was saturated with said powder, and it
denies that complainant breathed said powder and that said
powder adhered to all parts of her body on a clothing, and it
has no knowledge or information sufficient to form a belief that
upon returning home, complainent's clothing and parts of her
body would be luminous in the dark; it denies the remaining
allegations of Paragraph 1.
2. Answering Paragraph 2, defendent has no knowledge
or information sufficient to form at belief as to whether com-
plainant had no knowledge whatsoever as to the ingredients
10h she mixed together to form the said paste; it has no
knowledge or information sufficient to form a belief as to whe-
ther the complainant knew that the application which she made
to the dials of watches was for the purpose of rendering the
numerals on said diels luminous in the dark; likewise, it has
no knowledge or information sufficient to form a belief as to
whether the complainant, from the name of the defendent cor-
poration, drew the inference that an ingredient of the sub-
stance she applied was redium; it dentes that radium is common-
ly known to have the characteristics of luminosity in the dark;
18 denies that the infinitesimel amount of radium or radio-
active substances contained in the said paste or paint or mix-
ture was dangerous; it has no knowledge or information suffi-
cient to form a belief as to what skill or knowledge of physics
or chemistry complainant had, and it has no knowledge or infor-
mation sufficient to form a belief as to how well informed the
complainant was with respect to the contents of said mixture;
it denies the remaining allegations of Paragraph 2.
3. Answering Paragraph 3, the defendant denies the
first sentence of said paragraph, but admits that at times seid
mixture or point used by the compleinant contained infinitesimal
portions of radium, mesothorium or thorium X; it denies that
said infinitedual portions of said radium, mesothorium or
thorium X, as used in said paint or mixture, were highly denger-
ous and destructive to bodily tissues when brought into close
proximity therewith, and it further denies that the defendent
OF its agents or servents in charge of its operation, knew
that said infinitesimal portions aforessid of said radium,
mesothorium or thorium x, were highly dangerous and destructive
as aforeasid; it denies the remaining allegations of Paragraph
3.
4. Answering Paragraph 4, defendent denies that it
well knew that the infinitesimel portions of sei a radium, meso-
thorium or therium X contained in said paint or mixture were
exceedingly harmful to bodily tissues when brought into close
proximity therewith; it admits it gave the complainent no
warning of any such alleged hermful condition of said paint or
mixture; it denies that it constantly instructed and required
complainant to be in close proximity with said radionative
substances, and it denies that the complainant was exposed to
the rays of said radioactive substances and the emanations
thereof, except that it admits that the complainent came in
contact with the paint or mixture aforessid containing an
infinitesimal amount or quantity of radium, mesothorium or
thorium X; it denies that the compleinant ingested radioactive
substances to her great damage, as a result of which complainent
through the period set forth in Paragraph 1 of the said bill of
complaint, constantly absorbed quantities of redionative sub-
stances until her body became impregnated throughout with such
radioactive substances; it denies the remaining allegations of
Paragraph 4, except that it admits that complainant was not
instructed or warned of the alleged dangerous nature of said
paint or mixture, and it further denies that said paint or mix-
ture was of a dangerous nature.
5. It has no knowledge or information sufficient to
form a belief as to the allegations of Paragraph 5.
6. It denies Paragraph 6, except that it admits that
complainant was finally successful in instituting suit.
7. It admits Paragraph 7.
8. Answering Paragraph 8, it denies tist the defend-
ant corporation, prior to and during the period referred to
in Paragraph 1 of the bill of complaint herein, knew that the
infinitesimal quantities of redionative substances used in
said paint or mixture, were of a dangerous and lethal nature,
and it further denies that anid paint or mixture was, in feet,
of a dangerous and lethal nature, and it denies that the com-
plainant was exposed to dangerous substances when she was ex-
posed to said paint or mixture; it denies the remaining allega-
tions of Paragraph 8 except that upon information and belief
it alleges that an alleged autopay was performed by the county
physician on two deceased persons who were formerly employees
of the defendant, and except further that it admits a report
of an alleged investigation was published in The Journal of the
American Medical Association in December 1925.
9. Further answering the bill, this defendent says that
the complainant 18 in gross Anohes; that the complainant claimed
to know that her alleged illness or illnesses were due to suid
alleged paint and the rediosctive substances alleged to be con-
tained therein long before the institution of the action at law
by the complainant against this defendent and long before the
bill of complaint herein was filed, and for the purpose of
bringing an action against this defendant the complainant em-
ployed counsel other then the complainant's present unsel of
record long before the institution of the setion et law by the
complainem against this defendent and long prior to the filing
of a bill herein.
10. Further answering the bill, defendent says that upon
the face of the bill it appears that there is no equity in
the bill.
COLLINS & CORBIN
Solicitors for and of counsel
with the Defendent.
IN CHANCERY OF NEW JERSEY
Between
KATHERINE SCHAUB,
Complainant,
Action at Law
and
UNITED STATES RADIUM COR-
PORATION, a corporation of
the State of Delaware,
Defendant.
ANSWER
COLLINS & CORBIN,
Sol'rs of Defendant,
1 Exchange Place,
Jersey City, N.J.
Page data
- Page
- 7
- Source index
- 0
- Type
- document
- Media ID
- 7b78faa356f55b9e
- Size
- unknown
Document data
- ID
- 75721940
- Core
- doc
- Type
- document
DTO data
{
"id": "75721940",
"sourceUrl": "https://catalog.archives.gov/id/75721940",
"contentType": "document",
"title": "Copies of Court Documents, September , 1927",
"citationUrl": "https://catalog.archives.gov/id/75721940",
"collections": [
"Safety Light Collection",
"Records Related to Radium Dial Painters"
],
"iiifBase": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001089_Page_1.jpg",
"thumbnailUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001089_Page_1.jpg",
"largeImageUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001089_Page_1.jpg",
"imageCount": 7,
"hasImages": true,
"source": "import",
"hasTranscription": false
}
Context sent to Scholar
Document identity
{
"localId": "75721940",
"label": "Copies of Court Documents, September , 1927",
"core": "doc",
"dtoType": "document",
"citationUrl": "https://catalog.archives.gov/id/75721940"
}
Document source metadata
{
"id": "75721940",
"sourceUrl": "https://catalog.archives.gov/id/75721940",
"contentType": "document",
"title": "Copies of Court Documents, September , 1927",
"citationUrl": "https://catalog.archives.gov/id/75721940",
"collections": [
"Safety Light Collection",
"Records Related to Radium Dial Painters"
],
"iiifBase": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001089_Page_1.jpg",
"thumbnailUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001089_Page_1.jpg",
"largeImageUrl": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001089_Page_1.jpg",
"imageCount": 7,
"hasImages": true,
"source": "import",
"hasTranscription": false
}
Document source extras
{
"url": "https://catalog.archives.gov/id/75721940",
"naId": 75721940,
"levelOfDescription": "fileUnit",
"recordType": "description",
"ocrSource": "nara-archive"
}
Page context
{
"seq": 7,
"pageIndex": 0,
"type": "document",
"url": "https://s3.amazonaws.com/NARAprodstorage/lz/electronic-records/SLC/Radium/SLC_0001089.pdf",
"mediaId": "7b78faa356f55b9e",
"ocrText": "IN CHANGERY OF NEW JERSEY\nBetween\n#\nKATHERINE SCHAUB,\n:\nComplainant, :\nand\n:\nOn Bill, to.\nUNITED STATES RADIUM COR-\n#\nPORATION, as corporation of\nthe State of Delaware,\n:\nDefendant.\n:\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 Jersey,\nsays that:\n1. Answering Paragraph 1 of the complaint here-\nin, while it admits that the complainant was employed by it\nduring a certain period of time, it denies that the complainant\nwas employed by the defendent from on or about the first day\nof February, 1917, to on or about the first day of July, 1920,\nand from on or about the 27th day of November, 1920, to on or\nabout the seventh day of June, 1921; it admits that complain-\nant's employment consisted in mixing a powder which defendant\ncorporation supplied to complainant, with glue and water, with\nwhich complainent was likewise supplied by the defendent, into\na paste of the proper consistency, which paste complainant the\napplied with a small camel hair brush to numerals on the dials\nor watches; it admits that said operation required some skill\nin the use of the brush with which it was necessary to mark\na fine line; it denies that in order to secure a fine point\nwith which to draw the necessary fine line with the brush,\ncomplainant was instructed by defendant to point said brush\nby putting the same in her mouth; it has no knowledge or in-\nformation sufficient to form a belief as to whether complain-\nant used to point said brush by putting the same in her mouth,\nand it denies that it was customery for complainant's co-wrkers\nto so point the brush; it has no knowledge or information suffi-\ncient to form a belief as to whether the brush, if or when\npointed by the lips, contained small quantities of said paste\nhereinbefore referred to, or whether some of said paste would\nremain on complainant's lips and was evan tually swallowed by\nher. It denies that said powder hereinbefore referred to,\nwhich was mixed into the paste, was very light and that the\nair in the workroom was saturated with said powder, and it\ndenies that complainant breathed said powder and that said\npowder adhered to all parts of her body on a clothing, and it\nhas no knowledge or information sufficient to form a belief that\nupon returning home, complainent's clothing and parts of her\nbody would be luminous in the dark; it denies the remaining\nallegations of Paragraph 1.\n2. Answering Paragraph 2, defendent has no knowledge\nor information sufficient to form at belief as to whether com-\nplainant had no knowledge whatsoever as to the ingredients\n10h she mixed together to form the said paste; it has no\nknowledge or information sufficient to form a belief as to whe-\nther the complainant knew that the application which she made\nto the dials of watches was for the purpose of rendering the\nnumerals on said diels luminous in the dark; likewise, it has\nno knowledge or information sufficient to form a belief as to\nwhether the complainant, from the name of the defendent cor-\nporation, drew the inference that an ingredient of the sub-\nstance she applied was redium; it dentes that radium is common-\nly known to have the characteristics of luminosity in the dark;\n18 denies that the infinitesimel amount of radium or radio-\nactive substances contained in the said paste or paint or mix-\nture was dangerous; it has no knowledge or information suffi-\ncient to form a belief as to what skill or knowledge of physics\nor chemistry complainant had, and it has no knowledge or infor-\nmation sufficient to form a belief as to how well informed the\ncomplainant was with respect to the contents of said mixture;\nit denies the remaining allegations of Paragraph 2.\n3. Answering Paragraph 3, the defendant denies the\nfirst sentence of said paragraph, but admits that at times seid\nmixture or point used by the compleinant contained infinitesimal\nportions of radium, mesothorium or thorium X; it denies that\nsaid infinitedual portions of said radium, mesothorium or\nthorium X, as used in said paint or mixture, were highly denger-\nous and destructive to bodily tissues when brought into close\nproximity therewith, and it further denies that the defendent\nOF its agents or servents in charge of its operation, knew\nthat said infinitesimal portions aforessid of said radium,\nmesothorium or thorium x, were highly dangerous and destructive\nas aforeasid; it denies the remaining allegations of Paragraph\n3.\n4. Answering Paragraph 4, defendent denies that it\nwell knew that the infinitesimel portions of sei a radium, meso-\nthorium or therium X contained in said paint or mixture were\nexceedingly harmful to bodily tissues when brought into close\nproximity therewith; it admits it gave the complainent no\nwarning of any such alleged hermful condition of said paint or\nmixture; it denies that it constantly instructed and required\ncomplainant to be in close proximity with said radionative\nsubstances, and it denies that the complainant was exposed to\nthe rays of said radioactive substances and the emanations\nthereof, except that it admits that the complainent came in\ncontact with the paint or mixture aforessid containing an\ninfinitesimal amount or quantity of radium, mesothorium or\nthorium X; it denies that the compleinant ingested radioactive\nsubstances to her great damage, as a result of which complainent\nthrough the period set forth in Paragraph 1 of the said bill of\ncomplaint, constantly absorbed quantities of redionative sub-\nstances until her body became impregnated throughout with such\nradioactive substances; it denies the remaining allegations of\nParagraph 4, except that it admits that complainant was not\ninstructed or warned of the alleged dangerous nature of said\npaint or mixture, and it further denies that said paint or mix-\nture was of a dangerous nature.\n5. It has no knowledge or information sufficient to\nform a belief as to the allegations of Paragraph 5.\n6. It denies Paragraph 6, except that it admits that\ncomplainant was finally successful in instituting suit.\n7. It admits Paragraph 7.\n8. Answering Paragraph 8, it denies tist the defend-\nant corporation, prior to and during the period referred to\nin Paragraph 1 of the bill of complaint herein, knew that the\ninfinitesimal quantities of redionative substances used in\nsaid paint or mixture, were of a dangerous and lethal nature,\nand it further denies that anid paint or mixture was, in feet,\nof a dangerous and lethal nature, and it denies that the com-\nplainant was exposed to dangerous substances when she was ex-\nposed to said paint or mixture; it denies the remaining allega-\ntions of Paragraph 8 except that upon information and belief\nit alleges that an alleged autopay was performed by the county\nphysician on two deceased persons who were formerly employees\nof the defendant, and except further that it admits a report\nof an alleged investigation was published in The Journal of the\nAmerican Medical Association in December 1925.\n9. Further answering the bill, this defendent says that\nthe complainant 18 in gross Anohes; that the complainant claimed\nto know that her alleged illness or illnesses were due to suid\nalleged paint and the rediosctive substances alleged to be con-\ntained therein long before the institution of the action at law\nby the complainant against this defendent and long before the\nbill of complaint herein was filed, and for the purpose of\nbringing an action against this defendant the complainant em-\nployed counsel other then the complainant's present unsel of\nrecord long before the institution of the setion et law by the\ncomplainem against this defendent and long prior to the filing\nof a bill herein.\n10. Further answering the bill, defendent says that upon\nthe face of the bill it appears that there is no equity in\nthe bill.\nCOLLINS & CORBIN\nSolicitors for and of counsel\nwith the Defendent.\nIN CHANCERY OF NEW JERSEY\nBetween\nKATHERINE SCHAUB,\nComplainant,\nAction at Law\nand\nUNITED STATES RADIUM COR-\nPORATION, a corporation of\nthe State of Delaware,\nDefendant.\nANSWER\nCOLLINS & CORBIN,\nSol'rs of Defendant,\n1 Exchange Place,\nJersey City, N.J."
}