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OCR Page 1 of 8JERSKY SUPREIE COURT
COUNTY
CONNOLLY and
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THOZAS COMNOLLY, hor husband,
a
Plaintiffs,
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VS.
ACTION AT LAU
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UNITED STATES RADIUN
COMPLAINT
CORFORATION (formerly Redium
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Luminous Natorial Corp.), a
corporation of the State of
t
Dolaware,
:
Defendant.
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Plaintiffo, Catherine Connolly and Thoma Connolly, her
busbend, residing in the City of Nesark, County of Essex and State of
Sew Jersey, complnining of the defendent, any that:
FIRST COUNT
l. At the tinos heroinafter sentioned, the defendant was
gaged in the business, anong other things, of and distribut-
ing radiun and redium products and menufacturing and distributing radim
and other Inninous materials.
2. The plaintise Catherine Connolly was employed by the de-
fendant for a period of time from 1917 to 1924 at its plante in the Cities
of Nowark and Ogange, Now Jorsey.
3. At the time and place aforesaid, the said pleintiff uss
directed by the agenta end servants of the defendant to mix certain lun
inous naterials into paint and to apply the and paint to the surface of
various cardboard and notal naterials, principally used in the senufacture
of vatches, clocka and Iuminous signs.
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