Letters Received to C.B. Lee, August 28, 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 August 28, 1934. RE: Sullivan vs. United States Radium Corporation. C. B. Lee, Esq., President, United States Radium Corp. 535 Pearl Street, New York City Dear Mr. Lee:- The above case is one in which we are appearing for your company as per your letter of April 13th, 1934. We have been having proceedings in court with respect to obtaining from the plaintiff as complete a bill of particulars as practicable. We have now reached the point where we are about to file answer. I am also request- ing from our adversary physical examinations, including an x-ray examination. These, we are undoubtedly entitled to, and if they are refused we will have to go into court and obtain an order compelling them. I am also going to try to obtain a testimonial examination before trial. In order to obtain that it is necessary to obtain the consent of our adversary since we are not entitled to it as a matter of right. It has also occurred to me that it might be wise to have a special investigator check up on the plaintiff for the purpose of ascertaining her present activities, including her employment, her health, her home life, etc. We had a detective by the name of William McCarthy do s ome of this work for us before although I think he is too expensive to use as he charges $20.00 per day plus expenses. We could probably get a Pinkerton de- tective for $10.00 a day. On the other hand, I think per- haps an ordinary investigator who investigates cases of this type for insurance companies might be the best kind of a man to have. I suggest that we have a conference at your earliest convenience for the purpose of deciding just how far we should go in the preparation of the case. AUG 29 1934 With kindest regards, Sincerely yours, EAM:LB Tamally