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April 14,1930.
The Globe Indemnity CO.,
Mr. Chas. Stockdell Gray,
20 Washington Place,
Newark, N.J.
Dear Sir:
We are sending you herewith by registered mail original
Summons and Complaint instituting action against us by Frances
Tappen Hoare, thru her attorneys Schneider and Schneider.
The complaint was served on the Corporation Trust Company,
our New Jersey Representative at 11:28 A.M. April llth, 1930.
You will note that the plaintiff states that she worked
for the United States Radium Corporation during part of the year
1916 and part of the year 1017, not giving any specific date as to
her employment or date of leaving our employ. Tie do not find among
our employment records that Frances Tappen Hoare was ever employed
by us - however, our records are not any too complete and it is
quite possible that she was employed during the time she claims.
We shall have to depend upon the testimony of this woman to establish
the period during which she was employed by us.
This case apparently comes under the period of your coverage
only, and possibly a short time prior to the time when we carried
compensation insurance.
If there is any information which you may desire from us
in preparing the answer, we shall be only too glad to cooperate.
Very truly yours,
Vice Prosident.
enc.
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"ocrText": "April 14,1930.\nThe Globe Indemnity CO.,\nMr. Chas. Stockdell Gray,\n20 Washington Place,\nNewark, N.J.\nDear Sir:\nWe are sending you herewith by registered mail original\nSummons and Complaint instituting action against us by Frances\nTappen Hoare, thru her attorneys Schneider and Schneider.\nThe complaint was served on the Corporation Trust Company,\nour New Jersey Representative at 11:28 A.M. April llth, 1930.\nYou will note that the plaintiff states that she worked\nfor the United States Radium Corporation during part of the year\n1916 and part of the year 1017, not giving any specific date as to\nher employment or date of leaving our employ. Tie do not find among\nour employment records that Frances Tappen Hoare was ever employed\nby us - however, our records are not any too complete and it is\nquite possible that she was employed during the time she claims.\nWe shall have to depend upon the testimony of this woman to establish\nthe period during which she was employed by us.\nThis case apparently comes under the period of your coverage\nonly, and possibly a short time prior to the time when we carried\ncompensation insurance.\nIf there is any information which you may desire from us\nin preparing the answer, we shall be only too glad to cooperate.\nVery truly yours,\nVice Prosident.\nenc."
}