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-2- was added to the basic sino sulohide mechanically, and the amount varied from one (1) part in 140,000 to one (1) part in 33,000. Inasnuch as it was not a loaded brush which was #pointed", but the dry brush, it is obvious that at the worst the amount of radio-active aine sulphide that could be ingested per day would be very small. However, as snall as this amount must have been wa have found a few cases where the system has absorbed some of the radioactive constituents and it has been deposited thruout the bony skeleton. The deposit of this material has persisted after a period of several years, and it is now the theory that the continued action of the alpha particles from the redioactive materials 80 deposited has been the cause of many of the conditions reported among these employees. In 1925, tiro cases that vere diagnosed as suffering from the result of their employment by us brought suit suit for demages, and were settled. In June, 1928, there was a group of five cases, which had been given wide publicity, thru their efforts in endeavoring to obtain redress, by the press, these were also settled. These cases you probably are more or less familiar with thru such publicity, and the information which I gave you. Tie are now confronted with building a defense in four (4) more cases that hove been instituted against us. In this connection they charge us with contributory negligence, in that the did not provide proper precautions for these employees during the periods of their employeent from 1916 to 1924. Thay claim that it was common knowledge at that time that even small asounts of radioactive paterials taken into the system was deleterious, and that às was well known, and that we should have been aware of it. On the contrary we maintain that there was no reason why we should have been suspicious that even though very minute amounts had been ingested that there was any possibility of hasard arising from the practice. This conclusion was based primarily upon the fact that during this time radium chloride was administered internally for certain conditions under medical supervision, and that there had never been reported in the literature any untoward effects resulting from this practice. We further maintain that even though wo hed been aware that small amounts of luminous sine sulphide were being ingested daily we should not have viewed this with any particular alarm, due to the fact that the radium or mesothorium, as the case might have been, was percipitated upon the sufface of the aine sulphide in an insoluble form - that is the sulphate, and knowing that radium sulphate is one of the most insoluble inorganic compounds known we should have felt a certain amount of confidence that the material would of necessity pass thru the alimintary tract without any appreciable amount being absorbed. It is in this connection that we are endeavoring to enlist the aid of nen in the medical profession vhose standing is unquestionable, and who have had experience in this type of sedication. As you know the number of men qualified in this particular line is very limited, and we are, therefore, appealing to you to assist us by allowing us to take your deposition to the effect that you either administered directly, or that under your supervision radium chloride was administered for the relief of certain pathalogical con- ditions. Also that yrou were in the main familiar with the literature upon the subject, and that as far as you know there had never been an untoward effect reported, and that in your experience you know of no untoward effects with the use of this type of medication. lie propose to thereby establish that up until 1925, we may Bay that the use of radium chloride internally

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    "ocrText": "-2-\nwas added to the basic sino sulohide mechanically, and the amount varied from\none (1) part in 140,000 to one (1) part in 33,000.\nInasnuch as it was not a loaded brush which was #pointed\", but the\ndry brush, it is obvious that at the worst the amount of radio-active aine\nsulphide that could be ingested per day would be very small. However, as\nsnall as this amount must have been wa have found a few cases where the system\nhas absorbed some of the radioactive constituents and it has been deposited\nthruout the bony skeleton. The deposit of this material has persisted after\na period of several years, and it is now the theory that the continued action\nof the alpha particles from the redioactive materials 80 deposited has been the\ncause of many of the conditions reported among these employees.\nIn 1925, tiro cases that vere diagnosed as suffering from the result\nof their employment by us brought suit suit for demages, and were settled.\nIn June, 1928, there was a group of five cases, which had been given wide\npublicity, thru their efforts in endeavoring to obtain redress, by the press,\nthese were also settled. These cases you probably are more or less familiar\nwith thru such publicity, and the information which I gave you.\nTie are now confronted with building a defense in four (4) more\ncases that hove been instituted against us. In this connection they charge\nus with contributory negligence, in that the did not provide proper precautions\nfor these employees during the periods of their employeent from 1916 to 1924.\nThay claim that it was common knowledge at that time that even small asounts\nof radioactive paterials taken into the system was deleterious, and that às\nwas well known, and that we should have been aware of it.\nOn the contrary\nwe maintain that there was no reason why we should have been suspicious that\neven though very minute amounts had been ingested that there was any possibility\nof hasard arising from the practice. This conclusion was based primarily\nupon the fact that during this time radium chloride was administered internally\nfor certain conditions under medical supervision, and that there had never\nbeen reported in the literature any untoward effects resulting from this\npractice.\nWe further maintain that even though wo hed been aware that\nsmall amounts of luminous sine sulphide were being ingested daily we should\nnot have viewed this with any particular alarm, due to the fact that the radium\nor mesothorium, as the case might have been, was percipitated upon the sufface\nof the aine sulphide in an insoluble form - that is the sulphate, and knowing\nthat radium sulphate is one of the most insoluble inorganic compounds known\nwe should have felt a certain amount of confidence that the material would of\nnecessity pass thru the alimintary tract without any appreciable amount being\nabsorbed.\nIt is in this connection that we are endeavoring to enlist the aid\nof nen in the medical profession vhose standing is unquestionable, and who\nhave had experience in this type of sedication. As you know the number of men\nqualified in this particular line is very limited, and we are, therefore,\nappealing to you to assist us by allowing us to take your deposition to the\neffect that you either administered directly, or that under your supervision\nradium chloride was administered for the relief of certain pathalogical con-\nditions. Also that yrou were in the main familiar with the literature upon\nthe subject, and that as far as you know there had never been an untoward\neffect reported, and that in your experience you know of no untoward effects\nwith the use of this type of medication.\nlie propose to thereby establish\nthat up until 1925, we may Bay that the use of radium chloride internally"
}