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COLLINS & CORBIN
COUNSELLORS AT LAW
CLEMENT K. CORBIN
ROBERT J. BAIN
EDWARD A. MARKLEY
DAVID A. NEWTON
1 EXCHANGE PLACE
CHARLES w. BROADHURST
JERSEY CITY, N. J.
HOWARD F. MC INTYRE
FRANK A. BOEHLER
June 9, 1927.
Grace Fryer vs. United States
Radium Co.
Burton E. Emory, Esq.,
Manager, Claim Department,
Aetna Life Insurance Company,
100 William Street,
New York City
Dear Sir:
Supplementing our letter of the 7th instant,
please be advised that on the 8th instant we had a con-
ference with Mr. Josiah Stryker of Messrs. Lindabury,
Depue & Faulka, your assured's attorneys. He strongly
advised against pressing our motion to strike out the
complaint which ne had noticed for next Saturday because
he felt that while our position is well taken that the
statute of limitati ons had probably run, it may be that we
would not succeed because of the indefinite allegations
in the second count of the complaint as to when the injury
occurred; and secondly, he feared that so would merely
educate our adversazy on the point in question, viz., the
statute of limitations: and third, he feared that any pub-
licity that the case might get by arguing the motion to
strike out the complaint in court at this time might cause
other suits to be instituted by other employees who claim
that they were also injured.
In accordance with his desire, we abandoned our
motion to strike out the complaint and filed answer, copy
of which is herewith enclosed for your file.
We have requested Mr. Stryker to let us have any
data that he had available that would assist us in the pre-
paration of this case and he stated that he would go through
his files and get together such data as he thought would be
helpful and send it to us;
We also advised Mr. Stryker of your willingness to
place at our disposal the entire services of one investigator
as soon as we are ready for him. Mr. Stryker said he would
let us know when he was in a position to give us the varione
suggestions which he has for the Investigati of this case
so that it might be prepared for trial. As you know, we have
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"ocrText": "COLLINS & CORBIN\nCOUNSELLORS AT LAW\nCLEMENT K. CORBIN\nROBERT J. BAIN\nEDWARD A. MARKLEY\nDAVID A. NEWTON\n1 EXCHANGE PLACE\nCHARLES w. BROADHURST\nJERSEY CITY, N. J.\nHOWARD F. MC INTYRE\nFRANK A. BOEHLER\nJune 9, 1927.\nGrace Fryer vs. United States\nRadium Co.\nBurton E. Emory, Esq.,\nManager, Claim Department,\nAetna Life Insurance Company,\n100 William Street,\nNew York City\nDear Sir:\nSupplementing our letter of the 7th instant,\nplease be advised that on the 8th instant we had a con-\nference with Mr. Josiah Stryker of Messrs. Lindabury,\nDepue & Faulka, your assured's attorneys. He strongly\nadvised against pressing our motion to strike out the\ncomplaint which ne had noticed for next Saturday because\nhe felt that while our position is well taken that the\nstatute of limitati ons had probably run, it may be that we\nwould not succeed because of the indefinite allegations\nin the second count of the complaint as to when the injury\noccurred; and secondly, he feared that so would merely\neducate our adversazy on the point in question, viz., the\nstatute of limitations: and third, he feared that any pub-\nlicity that the case might get by arguing the motion to\nstrike out the complaint in court at this time might cause\nother suits to be instituted by other employees who claim\nthat they were also injured.\nIn accordance with his desire, we abandoned our\nmotion to strike out the complaint and filed answer, copy\nof which is herewith enclosed for your file.\nWe have requested Mr. Stryker to let us have any\ndata that he had available that would assist us in the pre-\nparation of this case and he stated that he would go through\nhis files and get together such data as he thought would be\nhelpful and send it to us;\nWe also advised Mr. Stryker of your willingness to\nplace at our disposal the entire services of one investigator\nas soon as we are ready for him. Mr. Stryker said he would\nlet us know when he was in a position to give us the varione\nsuggestions which he has for the Investigati of this case\nso that it might be prepared for trial. As you know, we have"
}