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OCR Page 1 of 2COLLINS & CORBIN
COUNSELLORS AT LAW
CLEMENT K. CORBIN
ROBERT J. BAIN
EDWARD A. MARKLEY CHARLES w. BROADHURST
1 EXCHANGE PLACE,
JERSEY CITY, N. J.
HOWARD F. MC INTYRE
FRANK A. BOEHLER
JAMES B. EMORY
PATRICK F. MC DEVITT
FRANK P. CLANCY
June 6, 1929.
Canfield V. U. S. Radium Corp.
Messrs. Potter & Berry,
60 Park Place,
Newark, N. J.
Dear Sirs:
Your representative this morning handed to
me in the above case a stipulation for the taking of the
testinony of Dr. Krumbhaar, Dr. Janes Ewing, Dr. Lloyd F.
Craver and Dr. Fialla, such testimony to be taken on the 27th
instent at two o'clook in the afternoon at the office of
Messrs. Miller & Chevalier, 111 Broadway, New York City, be-
fore Nicholas Bindseil.
We have no objection to the time and place,
provided the stipulation is so drawn as to clearly indicate:
1. That you are taking the testimony of these
men as your witnesses.
2. That the testimony is being taken de bene
essy that is, that it is to be taken and is to be
used only in the event that the itnesses cannot
be produced at the trial.
3. That we are to have the right to oross exemine
the witnesses.
4. We are to have the right to use the testimony
on the trial in the event that you do not do so, if
we in our judgment feel that we want to read it into
the record.
5. We are to receive a gopy of the testimony at
your expense.
As the stipulation is now drawn, it would apre ar
as though these witnesses were being called by both sides and
that we and you together were taking the testimony, whereas the
faot is that they are appearing as your witnesses in this pro-
ceeding and you are galling them to substantiate the allegations
contained in your complaint.
Yours very truly,
EAMIAG
Coun Corona
Relations
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