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    "localId": "75730587",
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    "id": "75730587",
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    "contentType": "document",
    "title": "Copies of Court Documents, no date",
    "citationUrl": "https://catalog.archives.gov/id/75730587",
    "collections": [
        "Safety Light Collection",
        "Records Related to Radium Dial Painters"
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{
    "seq": 6,
    "pageIndex": 0,
    "type": "document",
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    "ocrText": "NEW JERSEY SUPREME COURT\nServed\nJuly 3ru.\nESSEX COUNTY.\nTheodore Kuser, Administrator\nad prosequendum of the Estate\nof Hazel Kuser, deceased,\nPlaintiff,\n-vs-\nUnited States Radium Corp.,\nand Arthur Roeder,\nDefendants.\nAction at Law\nSUMMONS AND COMPLAINT\nKalisch & Kalisch,\nAttorneys of Plaintiff,\n790 Broad St.,\nNewark, N.J.\nNEW JERSEY SUPREME COURT\nESSEX COUNTY.\nTHEODORE KUSER, Administrator\n:\nad prosequendum of the Estate\nof Hazel Kuser, deceased,\n:\nPlaintiff,\n:\nAction at Law\n-vs-\n:\nUNITED STATES RADIUM CORP.,\n:\nCOMPLAINT.\nand ARTHUR ROEDER,\n:\nDefandants.\n:\nPlaintiff, Theodore Kuser, Administrator ad prose-\nquendum of the Estate of Hazel Kuser, deceased, residing at\n153 Watchung Avenue, West Orange, County of Essex and State of\nNew Jersey, Complaining of the defendants, says that:-\n1. The defendant, United States Radium Corp. at\nthe time hereinafter mentioned was and is now a corporation,\nhaving its principal place of business in the State of New\nJersey, and whose business consists, among other things, of\npainting numerals on faces of watches by means of brushes,\nin which work certain liquid is provided to the employees as\nhereinafter set forth; and defendant, Arthur Roeder, residing\nin East Orange, County of Essex and State of New Jersey, and\nat the time hereinafter mentioned, was president of the above\nmentioned United States Radium Corp. and acted for said corpo-\nration as its general manager, and in full charge of the plant\nlocated as above stated.\n2. For several years and until July,1920, when\nshe became incapacitated as hereinafter set forth, the plaintiff's\nintestate was employed at the plant of the United States Radium\nCorp. in and about the work of painting numerals on faces of watches,\nwith a brush, with a certain liquid provided by the defendants\nto the plaintiff's intestate, at its plant in the City of Orange,\nCounty of Essex and State of New Jersey.\n-2-\n3.\nWhile so employed by the defendants, the plaintiff's\nintestate was provided by defendants with a small brush which brush\nthe Plaintiff's intestate was obliged in the doing of her work to\ndip in a small crucible in which liquid material had been placed,\nthe same having been provided by the defendants to the plaintiff's\nintestate for that purpose. Before dipping the brush in the\nmaterial the plaintiff's intestate had been instructed by the\ndefendants, and the common practice had been ever since the\nplaintiff's intestate started to work for the defendants, to\nplace the brush in the mouth of the worker, and thereupon to dip\nthe said brush in the crucible containing the materials. That the\nliquid material and the brushes furnished by the defendants to\nplaintiff's intestate contained certain substances deleterious\nto the human body, to the knowledge of the defendants and of which\nthe plaintiff's intestate had no notice, knowledge or warning, and\nthe constant use of the same caused such deleterious matter to\nenter the system of the plaintiff's intestate; and it is further\nalleged that owing to the careless, negligent and improper manner\nin which the defendants ordered, permitted and suffered a certain\nproduct, known as radium, or other substance deleterious to the\nhuman body, to be used in and about the plant, fine particles of\nthe said substance were thrown into the air in close proximity to\nwhere the plaintiff's intestate was working and the plaintiff's\nintestate by reason thereof, in breathing carried into her lungs\nsaid particles, causing them to be filled with the said particles\nor substance and producing a diseased and injured condition.\n4. As a result of working continously at the work\naforesaid, the particles arising from the use of the radium or\nother substance deleterious to human life and limb, in some\n-3-\nmanner known to the defendants and unknown to the plaintiff's\nintestate, entered the system and circulation of the plaintiff's\nintestate, causing her great pain and suffering and a diseased\nand injured condition as a result of which she died.\n5. The defendants well knew and had notice that\nthe plaintiff's intestate would become impregnated and did\nbecome impregnated through her entire system with the substance\nhereinbefore described, and deleterious to her life and health,\nand furnished and used as aforesaid by the defendants, and\nnecessarily so by reason of the careless, negligent and\nimproper manner in which she was ordered, suffered and permitted\nto work by the defendants.\n6.\nNotwithstanding the defendants' knowledge and\nnotice of the danger, incident to the said employme.it of which\nthe defendants well knew, and further knew that plaintiff's\nintestate had no knowledge or notice of the same, the defendants\ndid not, at any time, inform or notify her of said dangers or\nany\nprovide/means by which this plaintiff's intestate and others\ndoing similar work could avoid the danger; and in no manner\nprovided any device or means of overcoming the danger, neither\ndid they provide her with necessary and proper means and treat-\nment to overcome the disability and injury caused her in the\ncourse of her employment.\n7. By means of the premises the plaintiff's intestate\nbecame entirely disabled and sick in limb and body and finally\nas a result of the disability and injury hereinbefore referred\nto, died on December 9,1924.\n8. Plaintiff says that the disability, injury and\nsubsequent death of Hazel Kuser was the direct result of the\nwrongful act,acts, neglect, carelessness and default of the\ndefendants above named as above set forth.\n9. This plaintiff brings into court letters of\nadministration granted by the Surrogate of Essex County to\nhim on April 23,1923, on the Estate of Hazel Kuser, deceased.\n10. That a cause of action has accrued to the\nhusband and next of kin of the said Hazel Kuser pursuant to\nthe statute in such cases made and provided.\n11. This action has been instituted within twenty-\nfour calendar months of the death of the deceased.\nPlaintiff therefore, demands as damages of the\ndefendants, the sum of Fifteen thousand ($15,000.00) dollars.\nSigned- Kalisch & Kalisch\nAttorneys of Plaintiff."
}