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Page -9- The complainants state that during their employment by us they were in good health, tre therefore had no reason to be suspicious that they were suffering from any complaint, regardless of whether it was due to their vocation oravocation. Not only do these employees state that their health was good during their employment but the history of all operators employed by us is very free from any physical complaint or disability. For this reason the matter was never brought to our attention that thein could possibly have been any hazard existing in connection with the work in our plant. If such a condition was unknown at this time mywhere else, and in fact even today it is impossible to find records of similar conditions appearing anywhere, except possibly in the Connecticut Valley, where the first case appeared in 1926. Mr. Viedt and Mr. Dey can establish that the general health of operators was probably above the average. 21. We have no knowledge as to when complainants were first informed of the nature of their illness. Hoffman had made an investigation and read a paper in May 1925. He presumably interviewed some of the complainants. The papers were full of sensational articles in June of 1925. Drinker in June 1924, reported on the Fryer case. The statement has been made that Drs. Davidson and Barry warned those treat- ed by them. This fact probably brought out in the Barry despostion. The fact that Dr. Martland made expired air tests on July 15,1925, and found radio- activity does not necessarily mean that the conditions claimed are due to employment at our plant. Martland's technique on making the tests may be successfully questioned. That Dr. Martland established that these girls were radio-active does not prove, by any manner of means, that that constituted the first knowledge these girls had that radium could be the cause of their trouble. In fact Miss Freyer told Dr. Flinn and Mr. Barker, on July 9,1926, that Dr. Eneff had interviewed her prior to her confimement at the Reconstruction Hospital, stating that he was the only one that Inew anything about jaw necrosis such as she had, and pleaded with her not to enter such a hospital. The details of this point have been covered in a previous paragraph. It is reasonable to suppose that Miss Freyer was aware that her trouble might possibly be ascribed to radium long prior to the test made by Dr. Martland. Dr. Kneff claims to have treated the Maggia girl, who died in 1922, and to have extracted a portion of her jaw which he ascertained to be radio-active. Dr. Kneff gives no dates as to the time when he discovered that the section of the jaw bone removed was radio-active, but he also claims to have treated Miss Vaggide sisters, namely - Mrs. Quinta licDonald and Mrs. Albina Larice, and it is therefore, probable to assume that Dr. Kneff advised these girls as to their probable condition. This is a point that should be developed. It will be important to thoroughly establish that Dr. Taylor and were correct in their diagnosis of X-Tay plates taken of Mrs. Larice and Miss Hussman, justifying their diagnosis that these cases were radium cases. Indications are that Dr. Humphries has been a little prone to diagnosis any case coming to his attention, who had been employed by us, as a radium case. This point is very important, and must be thoroughly established. Miss Wiley toocirculated literature relative to the condition existing in our plant, and it is important to establish whether Wiley interviewed any of the complainants in this action, and the nature of her interview.

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    "ocrText": "Page -9-\nThe complainants state that during their employment by us they were in good health,\ntre 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 thein could possibly have been any hazard existing in connection\nwith the work in our plant. If such a condition was unknown at this time mywhere\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\nfact\nthat Dr. Martland made expired air tests on July 15,1925, and found radio-\nactivity\ndoes not necessarily mean that the conditions claimed are due to employment\nat our plant.\nMartland'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.\nIn fact Miss\nFreyer told Dr. Flinn and Mr. Barker, on July 9,1926, that Dr. Eneff had interviewed\nher prior to her confimement at the Reconstruction Hospital, stating that he was\nthe only one that Inew anything about jaw necrosis such as she had, and pleaded with\nher not to enter such a hospital.\nThe 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.\nDr. Kneff claims to have treated the Maggia girl, who\ndied\nin\n1922,\nand\nto have extracted a portion of her jaw which he ascertained to\nbe radio-active.\nDr. 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 Vaggide sisters, namely - Mrs. Quinta licDonald 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.\nIt will\nbe important to thoroughly establish that Dr. Taylor and were correct in\ntheir diagnosis of X-Tay 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 toocirculated literature relative\nto the condition existing in our plant, and it is important to establish whether\nWiley interviewed any of the complainants in this action, and the nature of\nher interview."
}