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OCR Page 1 of 2William D. Edwards
Edwin F. Smith
Edwards, Smith & Dawson
No.1. Exchange Place
Raymond Dauson
Charles M. Jumes
Attorneys & Counsellors, at Law
Jersey City.N.J.
Forrest S...Smith
Allen b. Mathias
Montgomery 5-2035
George Echelman
Edwards & Smith
March 20th, 1934.
United States Radium Corp.
535 Pearl Street,
New York, N.Y.
Att: Mr. H. H. Barker
Re: La Porte V. U. S. Radium Corp.
Dear Mr. Barker:
We enclose herewith a copy of Answers to
Interrogatories, which we have to send to plaintiff attorney.
Will you kindly read them over, and let us
know whether or not there is any statement of fact contained
therein which is untrue. The first question refers to length
of time that the Radium Company, mentioned in the Bill of
Complaint, had been in operation up to 1918. The Answer is
drawn as it is, because the Company could not have maintained
the plant before its incorporation. Question #2, refers to
radium, mesothorium and thorium-x. Question #6, refers to the
length of time each plant was operated, and the other questions
are self-explanatory.
We wish you would examine the Answer to Interro-
gatory #34, with particular care. The question here is what
instructions were given to the operator with respect to the use
of radio-active material. If the answer as given is not complete,
please tell us what has been omitted.
Very truly yours,
Edmands Smith Damson
ACM:HS.
Encl.
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