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OCR Page 1 of 2COLLINS & CORBIN
REOEI D
COUNSELLORS AT LAW
JUL 8 1927
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
July 7, 1927.
Katherine Schaub vs. United States
RADIUM LUWI
Radium Corporation, et al.
MATERIAL CC
C. B. Lee, Esq.
President, United States Radium Corporation,
535 Pearl Street,
New York City.
Dear Mr. Lee:
Herewith enclosed find copy of our answer in
the above case; also copy of memorandum of telephonic con-
ferences in regard to the question of coverage.
May we request you to kindly check up on the
question of coverage and if you find that there are any
other insurance companies involved they should be notified
immediately, for our company has requested us to state that
it is not liable except for an illness contracted during the
policy per iod and that if it should appear from the investiga-
tion that the illness was contracted during a period other than
the policy period, it would not be liable for any judgment re-
covered and that it is to be distinctly understood that the
defense of the suit is with that reservation. A more difficult
question will probably arise in the event that it appears that
the illness was contracted over a period of years only one of
which is covered by our policy. However, we presume that ques-
t ion can await future developments and we can cross that bridge
when we come to it.
We should also like to have a statement of the
exact times during which Katherine Schaub was employed by the
United States Radium Corporation. We should also like to know
the period of employment of Grace Fryer. You say her employ-
ment ceased on March 19, 1920. Over what period Or periods of
time prior to that was she employed by your company?
With respect to the conference which you suggest
in your letter to Mr. Stryker of the 24th ult. please be advised
that we shall be ready to attend any conference that Mr. Stryker
may call. We understand he is going on vacatio and will return
about August 8. He informed us that he would be pleased to ar-
range a conference shortly after his return.
Yours very truly,
Collins Cress
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