Memorandum, April 12, 1928

April 12th,1928 - at 19 Tranklin St.Newark,N.J The writer explained to Dr. S. that we were anxious to ascertain (1) whether or not plants enmag in application of luminous materials contain ing radium or radio-activo constituents, used a method similar to that which wa employed at our plant in Orange. That is does the general practice abroad consist of using fine camel's hair brushes for painting the numerals on watch dials, and do the operators point the brush with thoir lips, or did they do so at any time during the history of the industry. (2) Whether his survey brought to licht any condition abroad similar to that apparently existing among our former employees. Dr. S.'s reply to the first question was that he had no kmowledge. He further stated that he felt the matter of the law suite which we are defend- ing at this time was puroly a personal matter between us and the plaintiffs, and he could, therefore, see no reason why he should enter into the picture in any way. Ite stated that he could not testify without tsking sides, to speak, and he feels that hie connections with the State Department of Labor are such that he should not under any circunstances enter into this question. Dr. S. continued by saying that the information supplied him while he was abroad was strictly confidential in nature, and he felt that he would be betraying the confidence of those whom he interviered should he disclose such information as they gave him. Dr. S. is very determined in his attitude not to become involved in these lew suits, and stated that should he be called as an involuntary witness he might prove more detrimental than beneficial to us. This I attribute largely as a mesns of defense that Dr. S. put out to avoid our subpoenaing him as a witness. Mhile 1 called to his attention the fact that Dr. had been called by the plaintiffs, and that we could soe no objection to his appear- ing in the case - he frankily stated that Dr. MeBride was appearing much against his wishes. In the course of our conversation Dr. S. suggested that we obtain the information that he has (which frankly admitted that he Imors the method employed in the painting of watch dials abroad) in the game manner as he obtained same, that is, by sonding a representative abroad to interview those engaged in this line of industry. he sald that he would be alad to furnish us with the names and addresses of the people whom he interviesed, and would go so far as to write these people as to who me are, and recomment that they supply us with such general information as we might desire. I told Dr. S. that we would be ver glad to get this list and he promised to send it to 138. My reaction as a result of the interview with Dr. Scamalotali is that we would probably be better off not to call him as a witness, unless absolutely necessary. Dr. MeBride apparently has a detailed report of Dr. 8.°s survey of the situation abroad, and it is quite probable that we ean obtain the informa- tion which we desire throw Dr. McBride when la is placed on the witness stand by the plaintiffs. The objection to such a procedure is thnt we are not amare of the nature of the information which is going to develop. However, I do not see how it can prove particularly detrimental. HHBarkor :RH