Letters Received to H.H. Barker, Edwin F. Smith, June 22, 1934

COLLINS & CORBIN COUNSELLORS AT LAW CLEMENT K. CORBIN ROBERT J. BAIN EDWARD A. MARKLEY CHARLES w. BROADHURST 1 EXCHANGE PLACE, HOWARD F. MC INTYRE JAMES B. EMORY JERSEY CITY, N. J. PATRICK F. MC DEVITT JOHN F. LEONARD JAMES J. LANGAN ADOLPH s. HUMMEL CHARLES H. SCHAFER ENOS A. PYLE RAYMOND J. LAMB EARLE J. HARRINGTON June 22, 1934. La Porte V. U. S. Radium Corp. Edwin F. Smith, Esq., 1 Exchange Place, Jersey City, N. J. H. H. Barker, Esq., Vice Pres. U. S. Radium Corp. 535 Pearl Street, New York City. Gentlemen: Replying to Mr. Barker's letter of the 18th addressed to Mr. Smith and myself and reiterating my telephonic talk with Mr. Barker, it seems to me the best way to handle Dr. Schlundt is to have him come here in advance of the trial and take his testimony de bene esse. This will have several advantages. First, it will save considerable expense; second, we can coach Dr. Schlundt and have him read over the testimony of the doctors in Chicago. He will undoubtedly make a better witness if he is not in court than as a witness in court in the presence of a lot of people. There is no disadvantage I can see in taking his testimony before trial, since this case will be heard only before a judge without a jury. He would undoubtedly have to read the testimony before going on the stand. I understand Mr. Barker will try to arrange to have Dr. Schlundt come here sometime during the next month or two giving us advance notice as to when he will be here and we can then arrange with Mr. Emmerglick to take the testimony. I have spoken to Mr. Emmerglick and he is willing to do so. Yours ve IY truly, EAM:AG JUN 25 1934