Extracted text

OCR Page 1 of 2
William 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.