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to 1922 inclusive, in the ordinary course of its business, to work at the
preparation of a substance containing some or all of the radioactive materials
above mentioned, and in the actual application thereof to the dials and hands
of watches and clocks and other objects at the plant maintained by the
defendant in Orange, New Jersey.
8.
The defendant negligently and carelessly, and despite
its knowlege, actual and constructive, as to the dangerous and injurious
nature of these radioactive materials to human tissue, so conducted its
business and so caused the plaintiff to carry on her work, as to cause her
to ingest and inhale large quantities of solid and gaseous radioactive sub-
stances contained in and given off from the material with which she worked,
and likewise omitted and failed to supply her with reasonable, adequate
and safe tools, appliances, methods and working conditions for carrying on
her work, and on the contrary caused her to prosecute the same with unsafe,
dangerous and inadequate tools, appliances, methods and working conditions,
and likewise omitted and failed to warn her or apprise her of unusual risks
attending her employment known to it, and to its knowledge not patent and
observable to, and of which, the plaintiff was wholly ignorant, and likewise
omitted and failed to warn her or apprise her of the dangerous nature of the
radioactive materials with which she was working, and of which she was wholly
ignorant, and otherwise negligently and carelessly used and employed the
radioactive materials above mentioned in and about its place of business.
9.
As the proximate result of the negligence and care-
lessness of the acts and omissions of the defendant stated in the preceding
paragraph, radioactive materials were thus ingested and inhaled into the body
of the plaintiff and became in part, lodged and fixed in various organs and
tissues.
10. The nature of the several substances fixed and deposited
in the body of the plaintiff is such that they continue to remain potent and
active for many years and produce by their inherent natural properties de-
structive effects upon human bones, tissues and other portions of the body
an 18 1832
of which properties and actions the defendant was, in 1917, charged with
knowledge.
11. The fact of the injurious action and effect of radio-
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Context sent to Scholar
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"ocrText": "to 1922 inclusive, in the ordinary course of its business, to work at the\npreparation of a substance containing some or all of the radioactive materials\nabove mentioned, and in the actual application thereof to the dials and hands\nof watches and clocks and other objects at the plant maintained by the\ndefendant in Orange, New Jersey.\n8.\nThe defendant negligently and carelessly, and despite\nits knowlege, actual and constructive, as to the dangerous and injurious\nnature of these radioactive materials to human tissue, so conducted its\nbusiness and so caused the plaintiff to carry on her work, as to cause her\nto ingest and inhale large quantities of solid and gaseous radioactive sub-\nstances contained in and given off from the material with which she worked,\nand likewise omitted and failed to supply her with reasonable, adequate\nand safe tools, appliances, methods and working conditions for carrying on\nher work, and on the contrary caused her to prosecute the same with unsafe,\ndangerous and inadequate tools, appliances, methods and working conditions,\nand likewise omitted and failed to warn her or apprise her of unusual risks\nattending her employment known to it, and to its knowledge not patent and\nobservable to, and of which, the plaintiff was wholly ignorant, and likewise\nomitted and failed to warn her or apprise her of the dangerous nature of the\nradioactive materials with which she was working, and of which she was wholly\nignorant, and otherwise negligently and carelessly used and employed the\nradioactive materials above mentioned in and about its place of business.\n9.\nAs the proximate result of the negligence and care-\nlessness of the acts and omissions of the defendant stated in the preceding\nparagraph, radioactive materials were thus ingested and inhaled into the body\nof the plaintiff and became in part, lodged and fixed in various organs and\ntissues.\n10. The nature of the several substances fixed and deposited\nin the body of the plaintiff is such that they continue to remain potent and\nactive for many years and produce by their inherent natural properties de-\nstructive effects upon human bones, tissues and other portions of the body\nan 18 1832\nof which properties and actions the defendant was, in 1917, charged with\nknowledge.\n11. The fact of the injurious action and effect of radio-"
}