Letters Received to C.B. Lee, March 12, 1928

FREDERIC J. FAULKS LINDABURY, DEPUE & FAULKS J. EDWARD ASHMEAD JOSIAH STRYKER JOHN w. BISHOP, JR. PRUDENTIAL BUILDING WALTER D. BARKER TELEPHONE JAMES E. M. TAMS MULBERRY 1755 BURTIS S. HORNER 763 BROAD STREET, NEWARK, N.U. ALAN w. CARRICK EDWARD P. O'NEILL, JR. March 12, 1928. RE: FRAYER VS. U.S. RADIUM CORP. #3486-LDF for C. B. Lee, President, U.S. Radium Corporation, 535 Pearl St., New York City. Dear Mr. Lee, I have your letter of the 10th inst. I think it would be well to have Dr. Schlundt as a witness, although I think there will be some uncertainty as to the benefit which we will receive from the testimony of any of these experts until after we have had an opportunity to discuss the matter with them in some detail. If they will testify that prior to 1924 there was no reason to suppose that the use of the paint as used in your plant would cause trouble to the em- ployees that will be very helpful to us. If they can go farther and say that even after Dr. Drinker's report was made there was still grave doubt as to whether he was not mistaken that will also be helpful. The thing that I particularly wish to learn from an intervi ew with these men is as to how many qualifications they will impose on those two statements for I fear that they may so qualify them as to make their testimony as of little use to us. Yours wery truly, JS/EAS