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OCR Page 1 of 3UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
Vincent P. LaPorte, administrator
ad Prosequendum of Irene F. LaPorte,
deceased, and Vincent P. LaPorte,
individually, and Vincent P. LaPorte
General Administrator, etc.,
IN EQUITY
Plaintiffs,
)
NOTICE TO PRODUCE
-VS-
)
United States Radium Corporation,
a corporation of the State of
)
Delaware,
Defendant.
)
TO: United States Radium Corporation,
and Gollins & Corbin, Esqs.,
and Edwards, Smith & Dawson, Esqs.,
its attorneys:
SIRS:
TAKE NOTICE that you are required to produce at the final hearing of
this cause all correspondence received from the plaintiffs, or their attor-
neys, relating in any way to the claims and action of the plaintiffs at law
and in equity, also all books, records and documents relating to the employ-
ment by the defendant or any other person, of the plaintiffs' decedent, with-
in the control or custody of the defendant, including all records of payments
of salary or wages to the plaintiffs' decedent; and
Also all letters, comminications, reports and documents received by the
defendant from any person or persons whatever relating to methods, materials,
processes and operations carried on by the defendant in the years 1917 and
1918 or similar to those carried on in either of such years; and
Also all letters, communications, report and documents relating to the
methods, materiala and processes connected with the dial painting operations
of the defendant carried on in the years 1917 and 1918 or similar to those
carried on in the years 1917 and 1918, received from any person whatever.
Milton M. Unger (Signed)
ATTORNEY FOR PLAINTIFFS
LJ-
11/8/34
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