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OCR Page 1 of 5NEW JERSEY SUPREME COURT
ESSEX COUNTY,
QUINTA MCDONALD and JAMES
:
MCDONALD,
:
Plaintiffs,
:
vs
Action-At-Law
:
UNITED STATES RADIUM CORP-
COMPLAINT.
ORATION, a corporation of
:
the State of Delaware,
:
Defendant,
Plaintiffs, Quinta McDonald and James McDonald, residing in the
City of Orange, County of Essex and State of New Jersey complaining say
that:
FIRST COUNT.
1. From on or about March 1,1917 to March, 1919, the defendant,
United States Radium Corporation was a corporation engaged in the extrac-
tion 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 Jersey.
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 daid radio-
active 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 person of the plaintiff, Quinta McDonald where the
said plaintiff was lawfully entitled to be and the said defendant was
negligent in that it carelessly and negligently placed said substances so
that the plaintifi, Quinta McDonald was exposed to the penetrative rays of
the said substances, inhaled the dust of the said radioactive substances
and the emanations thereof and ingested the same to the plaintiff's great
damage.
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