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    "ocrText": "MEMORANDUM OF DEFENSE\nBased on Points Raised in Mr.BerrY's\nProposed Agreement on Facts.\n1. Claims in Paragraph 1 - admitted.\n2.\n(a) Contained Radium only until May 1919.\n(b) Contained Radium and Mesothorium in varying quantities from May 1919\nCan prove by - C. B. Lee or H.H.Barker\n3. It is admitted that the radio-active constituents contained in our luminous\npreparations were known since the year 1900, but it is denied that there was common\nknowledge relative to the destructive effects which might be incurred in the\nordinary handling or commercial production of this substance. The first real indica-\ntion of any such hazard was reported by the Radium Institute of London in their\nannual report of 1919, and even this report does not strongly predict that there is\na hazard existing, although they make certain recommendations for the protection of\ntheir employees who are engaged in the handling of relatively large quantities of\nradium.\nIn 1920 Mottram reports on three fatal cases occuring at the Radium Institute,\nand while he states that the proof is not conclusive that their deaths should be\nattributed to radium, still he feels that they could not deny the fact that it might\nhave been contributory. All of this work applies to the use of radium in high\nconcentration, as well as large dosage or amounts, and is comparable in no way to\neither the concentration or the quantity of radium involved in luminous paints. In\nfact there is no mention of such paints in the work reported at this time, even\nthough radium paints were in common use, especially in England. Again let us keep\nin mind that none of this work was directed to such quantities of radium as are\ninvolved in the handling of radium luminous material, but with quantities ranging\nfrom 100 to 1000 times such amounts. That the therapeutic value of radium was\nbased upon the destructive effect of this material to bodily tissues is somewhat\nfar fetched, on the contrary it would seem that as a result of the use of radium\nfor therapeutic purposes the fact that it was injurious under certain conditions\nbecame apparent.\nDrs. Moore, Schlundt,Lind, Flinn and if necessary Mr. Barker\n4. Probably no specific information was ever given to the complainants regarding\nthe material furnished them for use, but is was common knowledge that the material\ncontained radium, and was called radium, or radium paint by our employees. This\nis confirmed by the further fact that our name at that time was Radium Luminous\nMaterials Corporation.\n(1) Advertising, sales & publicity material posted at times on plant\nbulletin board.\n(2) Most of Plant devoted to production of Radium\nPage -2-\n5.\nClaims in Paragraph 5 - admitted.\n6.\nCannot verify ages of complainants at the time of their employment, but assume\nall were minors except one, as claimed.\n(1) If important, require proof of ages.\n7.\nIt is admitted that our officers and agents instructed the complainants to use\ntwo kinds of binders together with thinners for the application of luminous material\nto the dials of watches etc.\nIt must be born in mind that Sochocky was the technical director in charge of\nthe plant at that time, and the only officer of the Corporation who had any contact\nor authority there. Further, that he was responsible for the development of both\noil and water adhesive, and the general conditions under which they were to be used.\nHe undoubtedly instructed those directly in charge of the application plant with\nreference to these points.\nMessrs. Roeder, Viedt Lee and Dey.\n8.\nWe deny that the oil soluble paste contained nauseating elements, but admit\nthat the material contained in our oil adhesive was possibly more disagreeable to the\ntaste than our water adhesive. We further deny that anyone who swallowed our oil\npaste would necessarily vomit. This I should say would depend entirely upon the\nphysical condition of such person as swallowed the adhesive, together with the\nquantity swallowed.\nDr. Flinn\n9.\nThe water soluble adhesive was not tasteless adhesive, but had a less disagreeable\ntaste than the oil soluble adhesive. Quantity for quantity the water adhesive\nwas cheaper to produce than oil - but the use of water adhesive probably cost the\ncorporation considerably more than if oil had been, or could have been exclusively\nused.\n(a) The ingredients for enough oil adhesive to paint 5000 watch dials costs\n12$, plus labor and overhead of manufacturing.\n(b) The ingredients for enough water adhesive to paint 5000 watch dials costs\n4#, plus labor and overhead of manufacturing.\nNote: This is enough to supply the fastest workers for 1 month.\n(c) Oil adhesive will not spoil, and will remain in its original form until\nused up.\nPage -3-\n(a) Water adhesive is very perishable, and sours or spoils within\na few days, especially in warm weather. This meant that quantitie\nfar in excess of what was actually used was being constantly produo-\ned. We had a special laboratory employing two people devoting\ntheir entire time to the production of adhesives, whereas if oil\ncould have been used an hour or two per week could have produced\nample quantities. Cannot divide labor between oil adhesive and\nwater adhesive.\n(e) Expense of adhesives was never a consideration, as the most\nexpensive was negligable compared to the value of the luminous\nmaterial.\nAdhesives then and now are furnished to all of\nour luminous material customers without charge.\nNote: Ingredients under a & b would apply material valued\nat from $200.00 to $3000.00\n(f) The primary question then and still is - an adhesive that will\napply smoothly and adhere, without spreading or without injuring\nthe dial, and one that adversely affects the luminosity of the\nmaterial as little as possible, and did not discolor with age.\n(g) We painted two kinds of dials - metal and paper.\n(h) Water adhesive could not be applied directly to metal dials,\nas it would not adhere; and if a basë coat was used first there\nwas still the danger of a rust condition developing later on -\ntherefore, oil adhesive was necessarily used on metal porcelain\nand similar dials.\n(1) Oil adhesive could not be successfully used on paper as the oil\nin it had a tendency to spread, or run and thereby disfiguring the\ndial. Hence water adhesive was used on paper, and since the most\nof our application at that time was on paper dials we necessarily\nused more water adhesive than oil. (the oil in the adhesive would\nspread the same as it does from putty)\n(I) The problem of proper adhesive was a most important question at\nthat time, and still is. Sochocky was in charge of adhesive\ndevelopment, and was responsible for whatever was produced and used.\n(k) Similar adhesives were used in a similar manner by all of our\ncompetitors at that time, as well as now, and oftimes sales argu-\nment was based on the superiority of one adhesive over another.\nWater adhesive is a Gum Arabic mixture very similar to common\nmucilage. Similar to gun water as sold in art stores.\n10.\nThe operators used small camel's hair brushes, but were not instructed to point\nsaid brushes with their lips. The rule was the reverse, not on account of the\nthought of danger, but for sanitary reasons. The rule was never strictly enforced\nand many of the operators pointed the brushes with their lips. Some never followed\nthis practice. This could not have been a uniyersal practice as a result of\nspecific instruction, as complainants counted in paragraph 8, that they were instruct-\ned to use oil adhesive as well as water, and claim in Paragraph 9, that if oil\nPage 4-\nadhesive was swallowed it would cause vomiting. In paragraph 11, they attempt to\nset up the fact that quantities of the material must necessarily be swallowed, as a\nresult of the practice of pointing the brushes with the lips.\nIt has been further suggested that there was a time when the luminosity of our Undark\nwas not up to standard, and in search for some reason to account for this apparent\ndecrease in luminosity it was suggested that the contamination of the adhesive with\nthe saliva might possible be the answer, and for this reason the officers of the\nCompany called the attention of those directly in charge of the application department\nthat brushes should not be pointed with the lips, and insisted that such a rule be\nenforced. However, it must be remembered that operators for the most part were on\npiece work, and in order to make good money their work must be speedy, and we understand\nthat some of our agents told the operators that while it was against the rule to\npoint the brushes with their lips, still they could speed up their work materially by\nso doing. This information was conveyed to the operators by our agents, but our\nofficers and directors had no knowledge of such instructions.\nMr. Day, Miss Rooney ,Miss Smith and Mr. Viedt?\n11.\nWe have no definite knowledge that operators who pointed brushes in their mouths\nswallowed any radio-active substances or paste, in fact it does not seem logical\nto admit this claim, due to the fact that brushes used for art are pointed (regardless\nof method used)ir 8. practically dry state, that is after the brush has been used\nfor painting and prior to loading with further material for proceeding with the work.\nThat is the brush is not pointed after it contains a maximum quantity of such paints\nas may be used, but rather when it contains a minimum quantity of these paints and\nin a comparatively dry state. For this reason the amount of adhesive or luminous\nmaterial introduced in the mouth, by such girls as may have pointed the brushes with\ntheir lips, would be a minimum, and it is quite conceivable that ordinarily little\nor none would be introduced.\nFutthermore, even though small quantities of\nmaterial might have been conveyed to the lips it does not necessarily mean that such\nmaterial was swallowed.\nThe practice of pointing brushes with the lips is common\namong artists, but metallic poisoning does not result in all cases following such\na practice, even though the paints used as a rule contain such poisonous elements.\nIn fact the average tendency is to expectorate anything gritty or disagreeable to the\ntaste rather than swallowing same. It seems to us as though it would be \"dirt-\neaters\", so to speak, who would swallow such materials.\nMethod of pointing brushes can be established by plaintiffs or anyone familar with such\noperations.\nDr. Flinn.\n12.\nSinc sulphide the base of our luminous material has a specific gravity of 4, which\nmeans that it is four times as heavy as water. The substance is not fine like flour,\nbut is chrystalline in form and was put thru a screen from 80 to 150 mesh. Some idea\nof the weight of the zinc can be had from the fact that it took frequent stirrings\n(two or three times while painting a dial) to keep the material in suspense even that\nmixed with & heavy oil or water paste adhesive.\nIt is ridiculous to assume that our luminous material was light enough to be\nblown throughout the room in which complainents worked. and adhered to all nerte of\nPage -5-\nbody, clothing, etc. for if such were the case the loss of material involved would\nhave been tremendous over the period of time, and the walls etc. of the room in which\nthis work was done would have treen sufficiently radio-active to justify reclaiming\nradium from same. On the contrary Dr. Drinker offers proof that the dust collected in\nour application room, which he described as luminous sinc sulphide, did not show the\npresence of radium. Furthermore, we may mention that the lowest grade luminous\nmaterial which we prepare, if diluted ten fold would readily show its radio-active\nproperty if any radio-activity constituents were present.\nIt is true that the\nwalls, etc. of any room in which any radium operations are conducted become radio-active\nto a more or less degree, not on account of radium having been deposited on such\nwalls, but due to the decay of the gaseous disintegration products of radium, radon\nand the production of the solid decay products which deposit on the walls of such rooms\nrendering them feebly radio-active.\nIt seems to me as though Mr. Bilstein might be valuable in the support of the conten-\ntion claimed in this paragraph, inasmuch as he produced all of the phosphorescent\nzinc sulphide used, and would have undoubtedly noticed himself to be luminous after\nturning out the lights at night should his body have been covered with this material.\nThere is no reason to assume that the material is any lighter or has any more tendency\nto be blown about after it has been mixed with radio-active constituents rather than\npr&or thereto.\nFor the information of the court it might be well to display samples of zine\nsulphide, as well as method of transferring same to cružible, mixing with adhesive\nand applying. Also show Court screens on which luminous material has been dusted\nto display fact that the material is obviously granular and not flour-like. This\nwould tend to support the contention that the material is of such a nature that it\nwould/88 readily blown about and adhere to such bodies as it might come in contact\nwith.\nEstablish specific gravity of material by -\nDrs. Schlundt,Noore,Flinn,Lind,Barker,Nr. Bilstein and Mr. Dey.\n13.\nIt is denied that our employes breathed large quantities of luminous material\ndue to its being blown about the room for the same reason as outlined in paragraph\n12. Furthermore had they breathed such material the particles would naturally be\nremoved by the mechanism contained in the nostrils etc. for such purpose upon\nblowing the nose or cleaning by other means as may have been used. It is only such\npersons as breath through their mouth as would possibly have taken in material into\ntheir system, and such material would undoubtedly have been carried to the lungs\nrather than deposited around the gums The method of distributing the luminous\nmaterial to the operators, as well as their operations of mixing and applying, necess-\narily prevented the possibility of any great amount of this material becoming blown\nabout\nthe room. The material was given to the operators in wide mouth bottles\nfrom which it was transferred to small crucibles and immediately wet with adhesive,\nsuch wetting preventing it blowing about. Further more the rooms at all times were\nwell ventilated, and should this material have been blown about we assume that the\ngreater part of the material would have been removed from the room and at no time would\nhhere have been any appreciable amount in the atmosphere. The application room was\nkept unusually clean and benches were wiped up each night after the operators had\ncompleted their day's work. It was common to inspect the drawers furnished for the\noperators implements in order to see that they were clean and contained no accumulated\nluminous material or equipment not supplied by the Corporation.\nMiss Rooney Dey ,Mr. Barker ,Dr. Flinn and Mr. Viedt.\nhere 18 a question OI IACT to De determined.\n15.\nIt is denied that we or anyone else had any knowledge during the years\n1917 to 1921 that radium or mesothorium would have caused the bodily injury\nwhich the complainents in this action claim. While at the present time\nthere are facts which would seem to indicate that radium and mesothorium,\nunder certain conditions, might prove injurious, still even those having had\nconsiderable experience in this phase of the work, are unable to state what\namount of radium is injurious, and why certain prople apparently are store-\nhouses for radio-active constituents, while others are not, who apparently\nworked under the same identical conditions. How could we have warned the\ncomplainants about something which we knew nothing, a fact which will be\nestablished by Drs. Lind, Moore and Schlundt. All of those connected with\nthis phase of the work claimed to have discovered the disease. The first\nreport being in May 1926 by Dr. Hoffman. Later Dr. Martland claimed that\nhe had discovered a new disease, and several others have claimed similar\ndiscoveries. Certainly these men price to publishing their embodying such\nclaims searched the literature for reports of similar conditions existing\nprior thereto, otherwise they would not have put themselves in a position of\nbeing branded as fake discoverers.\nThe first direct knowledge which we had of any danger existing in our plant\nwas either late in 1923 or early in 1924 when Dr. Barry indicated that trouble\nwhich certain girls was suffering from probably due to their vocation, ascribing\nit to phosphorous, which of course was an error, at such time Dr. Barry knew\nthat our material contained no phosphorous, he after decided that it must\nthen be due to radium or radio-active constituents. We immediately got in\ntouch with the Life Extension Institute upon receipt of this information, and\nhad them make a thorough investigation of our employes for any industrial\nhazard which might prevalent in our plant - not aware however that there was\nany possibility that this trouble could be ascribed directly to radium. The\nLife Extension Institute reported that therewas no indication of an industrial\nhazard existing in our plant, and rendering such a report to the employes\nthemselves.\nDrs. Fisk, Lind, Schlundt, Flinn, Moore Mertland, Hoffman, Barker,\nRoeder, Viedt and Lee.\n16.\nIt is admitted that Dr. Geo. S. Willis was a stockholder, Director and\nChairman of the Board of Directors during the year 1917 - also that he used\nlarge quantities of radium therapeutically in his practice about Morristown,\nbut it is denied that Dr. Willis had any special knowledge regarding the\ndangerous nature of radio-active substances, which was evidenced by the\nfact that Dr. Willis did not exercise any particular precaution in handling\nhis radium. Dr. Willis had a total of approximately one gram of radium\nelement which he handled in bulk, and from which he suffered rather severe\nburns, eventually necessitating the emputation of some of his fingers.\nHad Dr. Willis been aware of the dangerous nature of radium it is nothing\nmore than probably to assume that he would have protected himself.\nAs previously indicated the note of warning was not common, or even\nrare that there was any particular injury in the handling of radio-active\nsubstances, until 1919 and subsequent thereto. This note of warning applied\nonly to cases where large quantities of radium were involved.\nThe quantity of radium which Dr. Willis\nPage -7-\npossessed was #ufficient when mixed with our luminous material to supply our\nmaximum force of operators (approximately 200) for a period in excess of 6 months.\nIt may be well to point out that prior to 1919 there was reported in the literature\ncases of over-exposure of radium on patients but never any indication of injury\nto people applying or manufacturing same.\nMr. Roeder can substantiate\nTohn\n17.\nSochocky resigned and left the Corporation May 24,1921. At this time he was\nPresident, and in charge of operations at Orange. Since 1917, he had been techni-\ncal director at Orange, and had charge of all development and operations. If he\nknew of any danger it was his duty to correct it, and he had the authority to do so\nwithout consulting anyone. He developed water adhesive, and for years it was made\nby him or in his laboratory or under his personal supervision. He never raised\nthe question of danger, or endeavored to restrain the use of water adhesive, with\neither Mr. A/ Roeder, then Treasurer and Mgr. of the Corporation, or Mr. Redmond\nCross, Chairman of the Board or Mr. W. H. Dey, who worked for Sochocky, and was in\ncharge of the Mechanical and Application Departments of the business. Sochocky\nleft the Corporation, not on account of the protest claimed, but entirely different\nreasons. He immediately started a competitive concern known as the General Radium\nCo. with offices at 149 Broadway and presumably manufactured luminous material\nunder the same formulae as used at our plant. He sold material to the Ansonia\nClock Co. and the Päcnser Instrument Co., both located in Brooklyn. Responsible\npersons will so testify. He supplied them both oil and water adhesives similar\nto that manufactured by us during his connection with the Corporation, without\ngivint-them any indication that there might be danger connected with the use of\nluminous material.\nThis can be substantiated by responsible people connected\nwith the Ansonia Clock Co., who state that they were unsware that there was any\npossible danger connected with this type of work until about the time articles\nappeared in the press (early 1925), they immediately communicated with us, and\nwe advised as to the steps which we had taken along these lines, especially with\nreference to the work which Dr. Flinn had done, and recommended that their employes\nbe examined by Dr. Flinn for any possible trouble that might be present among\ntheir employee or any latent possibilities of same.\nRepresentative from Ansonia, Mr. Dey,Mr. Roeder,Mr.Corss,Mr.Viedt.\n18.\nLead screens were not used in the Laboratories of the Corporation, even where\nlarge quantities of Radium Element in concentrated form was handled, until the\nemployment of Dr. Edwin D. Leman as Chief Chemist in Nov. 1920, who insisted on\nusing screens, altho Sochocky had been the Technical Director of the Corporation\nsince its formation. At the request of Dr. Leman screens were constructed in\naccordance with his specification. Sochocky cooperating with Dr. Leman in this\nwork, although there were no screens constructed for Sochocky himself. Sochocky\nPage -8-\nSochocky stated that when necessary he could use such screens as were built for Dr.\nLeman, but there is no evidence that Sochocky ever made use of such screens.\nFutthermore Sochocky handled large quantities of high grade salts over short\nperiods of time, and took little or no precaution himself which would tend to\nindicate that he had no idea that such small quantities as were contained in\nluminous material distributed to operators could possibly be dangerous. In fact\nSochocky was so careless in the handling of radium that he suffered very severe\nburns, due to radium. In fact Dr. Lind told us that he had never seen a worse\npair of hands on any man as those exhibited by Sochocky. We cannot give the\ndate of this except by that Dr. Lind can furnish some concrete information.\nWhile at is true that at times tongs were used to handle small glass tubes and\nneedles, the reason for this being not on account of any possibility of suffering\nfrom the effects of radium, but necessitated on account of the technique required\nin the sealing and preparing of these tubes for the trade.\nEven masks were\nused at times - but here again it was not for the reason of any possible danger\nbut to prevent any draft being caused during respiration shich might possibly\nresult in the loss of small quantities of the high grade radium salts as a result\nof dusting.\nDr. Sochocky and Mr. Bilstein probably compounded all of the\nluminous material during the period of 1917 to 1921, and neither one used any\ngarticular precaution.\nIn fact they both pippetted the radium solutions\nwhich were mechanically introduced into the luminous zinc sulphide without any\napparent injury to themselves. All of the mterial used in our plant, as well\nas the plants to whom we supplied luminous material, was prepared in this fashion,\nand the amount of radium so pippetted per year amounted to a matter of grams.\nIt was after Sochocky severed his connections with the Company that Mr. Bilstein\ndeveloped a system of graduated pippets for measuring out the solutions to be\nintroduced into the luminous material mechanically.\nMr. Bilstein would\nprobably be the most valuable witness to confirm the data in this paragraph, also\nMr. Viedt.\nOur Mr. Barker has been engaged in the commercial production\nof radium since 1915 and has at various times crystalised * tubesof high grade\nradium preparations. He states that up untia around 1921 or 1922 that he used\nno special precaution in either the original tubing of such preparations or\nretubing in accordance with specification of customers.\n19.\nWe will admit employment of the complainants as follows:\nMiss Grace Freyer - December 26th,1918 to March 19,1920\nVities Katherine Schaub - March 22,1917 to March 19,1920.\nMrs. Quinta McDonald, March 1,1917 to March 1,1919.\nMrs. Albina Larice - August 1,1917 to June 5th 1919.\nMrs. Edna Hussman - June 1,1917 to February 1,1922 ?\n20.\nl'e deny that the condition of the complainants was necessarily due to exposure to\nradioactivity, but admit that they may have had manifestations of illness on the\ndates specified. We deny that we had any knowledge that the plaintiffs'\nsystems were impregnated with radio-active materials, or that any illness ,whatever\nit may have been,resulted from their employment or radio-active materials should\nit be proven that they contained same. The plaintiffs state that during their\nemployment by us they were in good health, and we therefore had no reason to be\n44\nwes\nPage -9-\nThe complainants state that during their employment by us they were in good health,\nwe therefore had no reason to be suspicious that they were suffering from any\ncomplaint, regardless of whether it was due to their vocation oravocation. Not\nonly do these employees state that their health was good during their employment\nbut the history of all operators employed by us is very free from any physical\ncomplaint or disability. For this reason the matter was never brought to our\nattention that their could possibly have been any hasard existing in connection\nwith the work in our plant. If such a condition was unknown at this time anywhere\nelse, and in fact even today it is impossible to find records of similar conditions\nappearing anywhere, except possibly in the Connecticut Valley, where the first\ncase appeared in 1926.\nMr. Viedt and Mr. Dey can establish that the general health of operators\nwas probably above the average.\n21.\nWe have no knowledge as to when complainants were first informed of the nature of\ntheir illness. Hoffman had made an investigation and read a paper in May 1925.\nHe presumably interviewed some of the complainants. The papers were full of\nsensational articles in June of 1925. Drinker in June 1924, reported on the Fryer\ncase. The statement has been made that Drs. Davidson and Barry warned those treat-\ned by them. This fact probably brought out in the Barry despostion.\nThe fact that Dr. Martland made expired air tests on July 15,1925, and found radio-\nactivity does not necessarily mean that the conditions claimed are due to employment\nat our plant. Martland's technique on making the tests may be successfully\nquestioned.\nThat Dr. Martland established that these girls were radio-active\ndoes not prove, by any manner of means, that that constituted the first knowledge\nthese girls had that radium could be the cause of their trouble. In fact Miss\nFreyer told Dr. Flinn and Mr. Barker, on July 9,1926, that Dr. Kneff had interviewed\nher prior to her confimement at the Reconstruction Hospital, stating that he was\nthe only one that knew anything about jaw necrosis such as she had, and pleaded with\nher not to enter such a hospital. The details of this point have been covered\nin a previous paragraph.\nIt is reasonable to suppose that Miss Freyer was\naware that her trouble might possibly be ascribed to radium long prior to the test\nmade by Dr. Martland. Dr. Kneff claims to have treated the Magria girl, who\ndied in 1922, and to have extracted a portion of her jaw which he ascertained to\nbe radio-active. Dr. Kneff gives no dates as to the time when he discovered that\nthe section of the jaw bone removed was radio-active, but he also claims to have\ntreated Miss Waggids sisters, namely - Mrs. Quinta McDonald and Mrs. Albina Larice,\nand it is therefore, probable to assume that Dr. Kneff advised these girls as\nto their probable condition. This is a point that should be developed. It will\nbe important to thoroughly establish that Dr. Taylor and Humphries were correct in\ntheir diagnosis of X-ray plates taken of Mrs. Larice and Miss Hussman, justifying\ntheir diagnosis that these cases were radium cases.\nIndications are that\nDr. Humphries has been a little prone to diagnosis any case coming to his attention,\nwho had been employed by us, as a radium case. This point is very important, and\nmust be thoroughly established.\nMiss Wiley too,circulated literature relative\nto the condition existing in our plant, and it is important to establish whether\nMiss Wiley interviewed any of the complainants in this action, and the nature of\nher interview.\n22. Te admit of the letters from and to Dr. Hoffman. Dr. Flinn examined Miss Freyer,\nat the request of Dr. McCaffery, Surgeon Dentist who was treating Miss Freyer, and\nreported to Dr. McCaffery on what he found, and reported that Miss Freyer showed\napproximately ten (10) micrograms of radioactivity.\nIn the communication\nto Dr. Hoffman suggesting that Miss Freyer report to Dr. Flinn, it was the thought\nof the U. S. Radi Corporation that through Dr. Flinn and his collaborators that\nMiss Freyer might possibly receive suggestions which would be helpful in the\ntreatment of her condition.\n23. We admit of the letters from and to Dr. Hoffman. Dr. Flinn never examined but\ntalked with Miss Schaub at the request of Miss Wiley. See paragraph 41\nfor\ncomplete details.\n24.\nWe had no knowledge of possible injury to our employees, until immediately before\nthe engagement of Dr. Drinker. Furthermore how could we have known of any injry\nto our employees when we had no knowledge that they were ill. We concealed\nnothing from the New Jersey Department of Labor, except to withhold from them at\nthe outset Dr. Drinker's full report. We were justified in this \"defensive\" con-\ncealment as at that time we had two or three law suits pending, and were being\nthreatened by Dr. Knef that others would be instituted unless we met certain demands\nfrom him.\nOfficials of the Department of Labor should confirm this on cross\nexamination.\nIt can be established by Dr. Fiske, of the Life Extension Institute, that we went\nto him in all sincerety to establish, what if any trouble existed among our\nemployees. The investigation of the Life Extension Institute was prior to the\nDrinker investigation. The Life Extension Institute reported after investigation\nof all of our employees, that in their opinion no industrial hazard existed in our\nplant, and sent the full report for each individual to the individual themselves.\nDr. Drinker must have been convinced at the outset of his investigation that we\nwere genuinly sincere in our efforts to ascertain the cause of the trouble among\nour employees, through conferences with Mr. Roeder and Mr. Viedt, and other\nofficials connected with the Company.\nDr. Fiske,Mr. Viedt and Mr. Roeder.\n25. We admit receiving the Drinker report, but do not admit that the Drinker report\nconstituted conclusive proof that the illness prevelent among our employees was\ndue to radio-active substances, in fact in Dr. Drinker's conclusions he states that\nhe believes the \"Burden of proof rests with the person who would maintain that\nPage 11 -\nraddum has not in some way caused these necroses of the jaw as an effect hitherto\nnot observed under these conditions of exposure\". Dr. Drinker submitted no\ndirect proof, and reached his conclusions by a process of ellmination, or from what\nmay be termed as negative deductions. Furthermore Dr. Drinker states that the\neffects he observed had not hitherto been reported. Dr. Drinker's report con-\nstituted an examination of 22 employees at our plant in the Spring of 1924, among\nthese 22 employees there were only some 7 or 8 employed in the Application of\nluminous material. The employment of the others ranged all the way from office\nhelp to plant laborers, and in this respect Dr. Drinker's report is misleading, as\none would interpret the report, under the conditions, to be of those engaged in\nthe application of luminous material. When the list of employees is classified\none obtains an entirely different picture than if we consider the entire group as\ntypical of operators engaged in the application of luminous material. There is\nother evidence in the Drinker report which tends to discredit the thoroughness of\nhis investigation - such as the statement referring to the fact that luminous\nmaterial dust, which he collected in our application plant. did not exhibit tite\nproperty of radieactivity. Dr. Drinker, himself, states that the condition as\nfound in our plant has hitherto not been reported, and his bibliography, which he\nmaintains to be one of the valuable parts of his report, deals only with deep-ray\nexposure where relatively large amounts of radio-active materials are involved.\nThere is a difference of opinion as to whether the Drinker report constitutes final\nevidence, but in the opinion of those thoroughly versed in this subject, such as\nDrs. Lind, Morre, McCoy, Schlundt and Flinn, they do not believe the proof con-\nclusive.\nEven though we were inclined to question Drinker's findings, never-\ntheless we put into effect all the various precautionary measures which he\nrecommended.\nMr. Viedt, McBride Roach and Roeder\n26. We had in our employment competent scientists well versed in the subject of radio-\nactivity, particularly Drs. Hess and Leman. During a portion of the years from\n1917 to 1921, we believed Sochocky to be well versed in the subject. Until\nsometime after his leaving the Corporation in May 1921, we believed him to both an\nM.D. and a Ph.D. He so claimed and appeared before Scientific and Medical\nSocieties as such, as well as in Magasines of whde circulation. A check up by\ncorrespondence and by a foreign détective agency reveals no such man as ever having\nmatriculated at or graduating from the institutions from which Sochocky claims\ndegrees. He is undoubtedly an imposter.\nHe posed as an N. D. and treated\nplant employees - Mr. Viedt as well as others. He wrote perscriptions, and\nsigned them Dr. Sochocky. Twenty-three such prescriptions we have in our possess-\nion. If he is bold enough to take the stand, he should be shown no mercy (Mr. Dey\nalso)\nMessrs. Roeder, Lee, Viedt,\nSubstantiate Dr. Hess's standing by\nDrs. Moore, Lind and Schlundt.\nPage 12 -\n27.\nTo admit all in this paragraph.\n28. We admit having published and distributed the Bibliography referred to, and that\nit contained a section entitled \"Radium Dangers - Injurious Effects\", but deny that\nthis has any bearing whatever on the cases in question. The subject matter which\nis very limited, dealt only with dangers from exposure to large quantities of\nRadium in concentrated form. The Bibliography was published in 1922, a date sub-\nsequent to the employment of the complainants. If the Medical Profession was then\njust beginning to realize the possible dan ger from Radium burns, where large\nquantities wereused, it takes a wide stretch of the imagination to believe that we\nknew that the infintesimal amount of radium used in luminous material was injurious\nespecially at the time the complainants were employed.\n29. Mr. Roeder did endeavor to persuade Dr. Drinker not to publish his report, but\nnever tried to have Dr. Drinker change his opinions. Mr. Roeder encouraged Dr.\nDrinker to continue his animal experiments and to investigate other plants\napplying luminous material, with the hope the t a complete investigation might\nreveal conditi ons not so alarming a S claimed by Dr. Drinker.\nRemember Dr. Drinker's report was rendered in a comperatively short time, without\nany animal experimentations, and after he had examined a small number of luminous\nmaterials painters at our plant, although there were many plants in the country,\nemploying a greatmany more operators than we who were using material produced\nby us. Mr, Roeder wanted the industry investigated, which was not done in any\nsense of the word, by Dr. Drinker's reporting only on our plant, which at that\ntime represented a very small portion of the industry. The report was not with\nheld from those entitled to same (Department of Labor incident excepted) and\nDr. Flinn was given the Drinker report when he began, or soon after he began his\ninvestigation.\nMr. Roeder.\n30.\nWe have no knowledge of what investigation the Consumers' League of N.J. may have\nmade, except as it appears in the correspondence. Perhaps on the cross examina-\ntion of Miss Wiley much information can be brought out, such as:\n1. What is the \"harmless\" luminous paint?\n2. Whom did she see?\n3. What doctors and dentists did she interview?\n4. What was the cooperation from Dr. Hoffman\n5. What did the patients and Doctors tell her?\n6. What did Dr. Hoffman tell her\n7. What did they tell the girls\nPage 13 -\nWe may be able to prove by her testimony that the complainants knew of the cause of\ntheir condition long before they claim Drs. Martland, Taylor and Humphries told them.\nIf the complainants did not know, why did Hoffman call it Radium-Mesothorium necrosis\ndiff May 1925. If they did not know why did the Consumers League send out literature\non the subject attributing the cause to Radium?\n31. Dr. Frederick L. Hoffman's statistical investigation of those engaged in the applica-\ntion of luminous material was very limited, and not sufficiently brought to true\nconclusions regarding the industry as a whole. In order to have made a thorough\nsurvey of this subject Dr. Hoffman should have obtained data from other plants in\nthis country engaged in the application of luminous material, as well as abroad.\nDr. Hoffman's investigation apparently consisted of interviewing a few girls that\nhad been employed by us, and Doctors and Dentists treating them,who for some\nreason unknown to us, attributed their condition to radim. It should be developed\nthat the Doctors and Dentists, whom Dr. Hoffmen interviewed, must have intimated\nto him that their condition could be ascribed to radium, otherwise there was no\njustification for his making such an assumption. In the event the t Doctors and\nDentists so advised Dr. Hoffman, is it not probable that their patients were aware\nof their condition? Dr. Hoffman's paper was read in May 1925, and priorrto that\ntime he must have talked with Drs. Martland and Kneff, as well as Miss Wiley.\nIt would seem that there is a possibility that some of the complainants knew\nof their condition at a date earlier than what they claim on this basis.\nFurthermore it is possible that the girls had more in common than their occupation,\nas claimed by Dr. Hoffman, for instance Mrs. McDonald and Mrs. Larice are sisters\nof Miss Maggia, who died in 1922, and whose death certificate showed sphyilis as\na contributing cause. It was not infrequent that one girl used the brush of another.\nDrs. Hoffman, Kneff, Flinn and Miss Wiley.\n32. Have no knowledge as to what Dr. Drinker may have written to the N.J. Department of\nLabor. Can Bring out on cross examination, as it may show unethical conduct on\nDrinker's part.\n33. We first sent to the Department of Labor, soon after receipt from Drinker, the result\nof the examination of our employees. Later we sent a further pertion of the Drinker\nreport. This did not exonerate us or condem us. The Department saw a complete\nPage 14 -\nreport before it received a copy of same from us. This is the only incident in\nthe whole affair where it may be considered we attempted to conceal. The Vice\nChenceller called this \"defensive concealment\", and no doubt the officials of the\nLabor Department will substanniate us on this point, insofar as it is possible\nwithout placing themselves in a position to be criticized.\nThe La bor Department\nwas aware of the recommendations in the Drinker report, and knew that we had bought\nall of such recommendations into force. Further they concurred with us that part\nof these recommendations were impractical and gave their consent to our eliminating\nsuch of these recommendations as were impractical.\nWe had the fullest\ncooperation of the Labor Department in this regard, and they at all times were\nentirely aware of our actions. Upon the request of the Labor Department it\nmust be remembered that the complete report was sent to them, after which their\nattitude was no different than prior to the time that such report was not in their\nhands.\nMcBride,Roadh,Roeder.\n34. This answered in paragraph 33.\n35. Dr. Drinker's report was in no way misrepresented to the Labor Department, for\nwe never misquoted any statement made in his report. As previously indicated\nwe did not supply the Labor Department with the entire report originally, but\nthat cannot be considered as misrepresentation, especially in view of the fact\nthat Dr. Drinker had supplied the Labor Department with such report. At the\ntime of the receipt 6f the Drinker report there were several suits pending against\nus and we certainly were jusfified in endeavoring to protect our rights and\nbeliefs under such conditions. Dr. Drinker had been paid for his services, and\nwe would have been glad to have him continue his investigation and render us further\nservices go far as it were possible for him to do. We felt that his action was\nmost extraordinary, and from an professional standpoint quite unethical.\nMr. Roder\n36. Statement in this paragraph admitted.\n37. Dr. Flinn was brought into the picture in March 1925, by Dr. Gilbert Thompson\nPage 15 -\n38.\nStatement denied.\nI was in Boston, Harvard University, April 1925, to discuss\nwith Dr. Edsel the Tatra-Ethyl lead situation. Dr. Drinker was brought into the\nconversation, and after the lead situation had been cleared up I told Dr. Drinker\nthat I was going to study the radium question and asked him what his feeling was\non the subject, and what his findings had been. There was just a general discuss-\nion at that time.\nIn May 1925 at the head-quarters of the U. S. Public Health Service, at\na conference called by the Surgeon General to discuss the hazards of Tetra-Thyl\nLead, Dr. Drinker asked me how I was getting along with my radium work, and\nsuggested to me that I should get hold of his report to the U. S. Radium Corp., and\ntold me of his experience with the N. J. State Depart of Labor., and claimed\nthat the Company had not given the Department the full details of this report, and\nhe was very much afraid they would do the same thing with me, and suggested when\nI received the report from the U. S. Radium Corp., that I send the report on to him\nand he would tell me whether it was the complete report or not. On receipt of\nthis report sometime in May I wrote a letter which is quoted here (quote).\nOn the steps of the Surgeon General's building office Dr. Drinker told me tlat\nhe wanted to publish his findings, and alsked me what I thought about it, and I said\nthat if he thought the Company was crooked, that I certainly would take it up\nwith the Company, and publish it in spite of them if he thought there was crooked-\nness - but that he would have to use his own judgment in the matter, that I didn't\nthink a medical man had any right to supress a situation even if he had to mention\nnames.\nBetween the conference in Washington and January 8,1926 I saw Dr. Drinker several\ntimes and each time the radium question was discussed. I don't know just\nexactly the dates it was discussed as I was up and back to Harvard several times.\nThe men I have talked this over with are - Dr. W. S. Bean, Surgeon U. S. Public\nHealth Service - Dr. Frank Pedley - Dr. Arthur Pope and Dr. Pettit of Ottawa.\nWhen the Dunn case was sent in it was sent over to the hospital for regular\ndiagnosis of the case. All cases that looked suspicious coming to my attention\nwere handled in conjunction with the Presby erian Roosevelt, Waterbury Hospitals\nand in conjunction with the regular hospital staff.\n39.\nStatements admitted. Dr. Flinn has never passed as an M. D. He never makes\nexaminations as an M. D., but where such examinations are necessary always has\nthem made by an M. D.\n40.\nWe have no knowledge as to whether or not the complainants new Dr. F.B. Flinn's\nconnection with the U. S. Radium Corporation, but do know that Dr. Flinn advised\nMiss Wiley that he was working in cooperation with the U. S. Radium Corporation\nto investigate this industry. As far as we know Dr. Flinn never indicated to\nthe girls directly that he was working in coopration with us, although Miss Freyer\nhad reason to assume such inasmuch as at the time she was at Dr. Flinn's office\nMr. Barker was also there. Dr. Flinn's connection with the U. S. Radium Corpora-\ntion was with with the distinct understanding that we would give him our full co-\nPage 16 -\noperation, and that he would have absolute freedom of action, and the right to\npublish any findings which he saw fit.\nThe U. S. Rad ium Corporation paid the\nexpenses for such investigation as Dr. Flinn conducted at the time of the law\nsuits in 1925. None of this money was for Dr. Flinn's personal service, but\nto defray expenses in connection with his investigation.\nSince that time on\nvarious occasions contributing money to a fund utilized by Dr. Flinn for the\ncontinuation of his studies and investigation of this industry on a broader\nscale.\n41.\nWhen Miss Wiley asked permission to come over and see me at my office at the\nbuilding, at the suggestion of Dr. Alice Hamilton, I discussed freely with her\nmy findings up to date. She said that she wished that I would examine some of\nthe Orange girls, and said that she had the list of seven or eight girls whose\naddresses she would send and would try to persuade them to have an interview.\nShe mentioned Miss Schaub in particular, stating that Miss Sduab's own Doctor said\nthat there was nothing wrong with her whatever, that she had been examined by\nseveral neurologists and that all said that she was all right, but said they thought\nshe was neurotic, and probably had some stomach trouble. Miss Wiley said that\nif I would talk with her and tell her of my findings it might relieve her mind\nand make her optomistic as to her general condition. I received a letter from\nMiss Wiley giving me Miss Schaub's address, saying that she could not find the other\naddresses she promised me, and suggesting that I write to Miss Schaub. I received\na. letter from Miss Schaub in response to my letter, saying that she was too ill to\nleave her home and that if I was interested enough in her case to come down to her\nhome that she would let me see her. I 1gnored her letter completely, because I\nthought that if she was not willing to come to my home to see me or the University\nfor examination she was not worth bothering abut, especially after Miss Wiley's\nstatement. One Sunday in the next spring of 1926, I received a 'phone call from\nMiss Schaub introducing herself, because I did not remember her name at the time,\nand asking if she could come to the house to talk with me for a few minutes. I\ntold her to come on up. She arrived at the house shortly afterwards with a friend,\nand after the usual greetings she told me that she had a tooth in her head that\nwas bothering her and wanted to know what my advice was about having it taken out.\nI told her that the best thing she could do would be to go to a good dentist, explain\nto the man where she had worked, and if he thought that the tooth should come out\nthat 1 would risk it and have it done, as I knew other girls wh9 had worked at\nthe same thing and had teeth extracted but suffered no ill affects. I suggested\nthat she go outdoors and get all the sunshine she could, and also suggested to her\nthat if it was possible for her to come over to the office at Columbia University,\nwe would make examinations there. I made no examination, not even to look into\nher mouth. While she went to the lavoratory, her friend who came with her, told\nme about how she would remain in the house all the time, and would not go out with\nfriends, I told her to try to get her friends to get her out of doors as much\nas possible to get all the sunshine sheuould to take her mind off of her condition.\nThat is all I waw of Miss Schaub.\nAt the time of Miss Wiley's visit to my office I told her that I was working with\nthe U. S. Radium Corporat ion in trying to determine where the trouble lay in the\nindustry.\nPage 17 -\n42:43:44.\nDr. McCaffery, who was one of the Consulting Surgeons connected with the\nPresbyterian Hospital was called in to examine a patient which I had sent to the\nhospital for observance. I met Dr. McCaffery at the Pres. Hospital and discussed\nthis case with him both before and after his exmination - he said the condition\nin many ways were similar to the freyer case, and asked me if I would like to see\nthe Freyer case, and make an electrometric test on her. I said I should be very\nglad to do so, and he said he would send her over to my office some time when she\nwas in to see him. While I was away in N. H. the latter part of June or the first\npart of July 1926, Dr. McCaffery called up my Secretay and made an appointment for\nMiss Freyer to come to my office on July 9th. My Secretary notified me that she\nhad made the appointment and I came on from N.H. to see this case. I made an\nelectrometric test of Miss Freyer with a game ray èlectroscope, but because of\nthe atmospheric conditions did not make an examination of expired air, but asked\nher to come in some time in the fall. Miss Freyer was very friendly in her\nattitude, and we discussed her case very freely. I asked her if she had any objec-\ntions to my having an X-ray made of her Jaw, and she consented so we took her\nover to the Vanderbilt Clinic where the picture was read by the radiologist, Dr.\nLewis, then in charge. I also asked her if she would have any objection to may\ntaking a specimen of her blood, which privilege she granted me. We talked for\npretty nearly two hours about her case. She told me what she used to do at the\nplant and all of her troubles - said that when she was going to be sent over to\nthe Reconstruction Hospital for an examination Dr. Kneff came to see her and\nspent one whole Sunday afternoon trying to persuade her not to go to N.Y. for treat-\nment saying that he knew more about the treatment than anybody else, but she\ninsisted upon going to New York. She said \"the other girls are dead, I am still\nalive\". Miss Freyer at that time complained of pains in her lower limb, and I\nsaid that I was sorry she had not mentioned it at the time she was having the\nX-ray taken, that she might have had it X-rayed at the same time, and that when\nshe came back in the fall we would X-ray it to see if any bone changes had taken\nplace. Viss Freyer never returned to my office.\nMr. Barker was present at that time, because we were carrying on some other\nexperimental work, and he assisted me in making readings. Considering that Miss\nFreyer had been sent to me by her Doctor I sent a letter, July 10th, to .McCaffery\nstating what our electrometric test had been, also her blood and suggesting that\nif the treatment which was being tried on Miss Dunn to eliminate the radimm\nwas successful, that Miss Freyer undergo the same treatment. Ordinarily when\na doctor sends a patient into a laboratory for examination the man making examination\ndoes not discuss the case or give his findings to the patient. It is considered\nunethical, and it is for the Dr. to give the informtion if he thinks necessary\nhimself. Miss Freyer's blood picture was not completed while she was there,\nwith the exception of the red count, white count and Hemoglobin test. Her Hemoglobin\nat that time was 80, and in talking with her about her condition I told her that\nher blood condition was better than mine, inasmuch as my Hemoglobin at that time\nwas only 70 due to certain exposures which I had been undergoing with my industrial\nresearch work.\n45. At the time of investigation and all during the study, free discussion took place\nin the office between Dr. Bean and myself and any other Doctors who happened to\ncome into the office, about the radium case. We discussed it freely with Pedley,\nand Dr. Pope, one time the pendulum would swing one way and another time the other\nway. I had been unable to get any evidence, either in my animal work or from the\nphysical examination that would indicate the girls' condition were due to radium.\nI have studied Wattram's work at the Radium Institute of London, and I have\ncorresponded with men such as Dr. Pfahler and Dr. R. C. Williams, now Asst. Surgeon\nGenera 1 of the U. S. Public Health Servide and found a unamimous opinion that any\nundue exposre to radium or Y-rou is first indicated hv the blood nicture. and that\nPage 18 -\nthe London Radium Institute had adopted as a safety measure that a consistant\nwhite count below 6000 would be indicative of exposure and the person should be\nremoved from that exposure. 1 found from Dr. R. C. Williams that there was a low\nblood pressure among radium workers - menstral disturbances among women, and that\nthere was no indication in the laboratory of any reported case of bone necrosis,\nexcept where the glass seeds containing a large amount of radium caused necrosis,\nthese were reported by Dr. Clark of Philadelphia in 1923.\nWhen I heard that Dr. Martland was to read a. paper before the Pathological Society\nMeeting Nov. 1925, Dr. Bean and myself attended the meeting and after hearing his\nevidence felt that he made a very strong case from his view-point. Wondering at\nthe time why we had discovered no signs of radium exposure among the girls examined\nin the plants, outside of the Orange plant. I wrote to Dr. Drinker asking him\nif he would send me a copy of his blood findings on the employees of the U. S.\nRadium Corporation during his investigations. Under the influence of Dr.\nMartland's paper and discussion of same, I made the statement which has been\nattributed to me. At the beginning of our study we depended on the blood count\nfor any indication of radium exposure. In the late summer of 1925 we developed the\nelectrometric test, which permitted us to determine whether the body of any person\ncontained radio-active materials. As our examinations of different employees in\nthe dial painting industry continued with increasing numbers of girls examined\nand an inability to find any of them that were radio-active at all we came to the\nconclusion the last part of Spring of 1926 that radio-active material was not a\nhazard of the dial painting industry, and published our findings to that effect. \"\n46. We contend that complainants \"had information as to the cause of their illness\"\nprevious to the dates specified in Paragraph 21, on account of -\na. Miss Wiley's and Dr. Hoffman's activities, which began in late\n1924, and culiminating in Dr. Hoffman's paper in May 1925.\nb. Newspaper publicity in May and June 1925.\nc. Drs. Davidson & Barry, and possibly Dr. Knef\nd. Dr. Drinker's check-up. of course there is the difficulty of\nproving that these doctors told the complainants.\nHe reported on Miss Freyer specifically.\nWe cannot accept as conslusive Dr. Martland'd diagnosis by an expired air test for\nradioactivity, and the diagnosis by Drs. Taylor and Humphries, neither of whom\nknow anything but radio-activity. They state here that other doctors previously\nhad diagnosed differently. It would seem important to check these doctors. How can\nwe admit that they all were wrong, and that Drs. Martland, Taylor and Hunghries were\ncorrect.\nRemember the claimed disease had just been discovered and named\nin May, by Dr. Hoffman. The medical profession knew little regarding it.\nMartland himself had had no, or very little, experience in the subject of radio-\nactivity.\nThe question of amount, and what amount has been determined to be harmful is para-\nmount.\nThe amount Martland found in each complainant, and the method of\ndetermination are important.\nThe organization of the Corporation took place in 1917. The Company which sold\nits assets to the Corporation had been in operation since about 1915. Therefore\nthe industry, you might say, was just beginning, and of course the officers could\nnot possibly have had knowledge of danger, if Berry's statement is true that the\ndisease is \"latent or self-concealing\", and does not manifest itself until long\nafter exposure.\nPage 19 -\n47. So far as Mrs. Hussman is concerned she worked for the Luminite Corporation\noff and on, from 1922 to 1925. It seems that it will be difficult to fasten\nthe blame for her injury on the U. S. Radium Corporation. She was examined\nby Drs. Bean and Flinn in 1925, while employed by the Luminite Corporation.\n48. Statement in this paragraph admitted.\nRu"
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