Extracted text

OCR Page 1 of 3
July 16,1925 Aetna Life Insurance Co. Essex Bldg. Newark, N.J. Centlement Att. Mr. Edward Breen l'e this morning handed to you summons and complaint in a suit, in the amount of $15,000., instituted by Theodore Kuser, administrator of the estate of Hazel Kuser, deceased. You will note that the alleged injuries occurred to the said Tazel Yuser at a timo when our plant was covered by liability insurance through your company. Te also wish to call your attention to the fact that during the years 1919-1920, we were known as the Radium Inminous Material Company. Our name was changed to that of the United States Radium Corporation in September 1921, but there was no change whatever in ownership. through reorganizations or otherwise. For detailed information regarding this particular claimant whose maiden name was other than Kuser, we ask that you commicate with r.H.V.Veidt, our rice-president, in charge of production, located at our Orange plant. He will be able to furnish you with detailed information. The Amorican Mutual Liability Insurance Co. also has complete records on this individual. In conjunction with this particular suit we wish also to state that the American Mutual Liability Insurance Company is now defonding a similar action brought against us several months ago. There has been & great deal of preparatory work done on this case and we feel confident that the American Mutual will be only too glad to give you the benefit of investigations to date. We have aesociated with the attorney of the Amorican Motual our own attorneys, the firm of Lindabury, Depue & Paulks of Newark. Mr. Styykor and Mr. Tamm of that office have been actively cooperating in the pre- paration of the defence. We shall be very glad to have Lindabury's office cooperate with your attorneys to the fullest extent and therefore suggest that before filing the answer to the Kuser suit, that your counsel re- ceive the benefit of what has been done so far. You will please note that the expication date for the filing of the answer is July 22nd.