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Questions for direct examination of Dr. Herman Schlundt: 1. Are you familiar with radioactive measurements? 2. Explain to the Court what you mean by radioactive measurements? 3. What is the difference between Emanation and gamma ray measurements? 4. Have you made both types of measurements? 5. Are you familiar with expired air method of making radioactive determinations as practiced by Mrs. Hughes? 6. How sensitive do you consider these determinations? 7. In other words what quantity of radium would be necessary in the body to produce an appreciable count by this method? 8. Have you examined plaintiffs by this method? 9. Have you examined data submitted by Mrs. Hughes? 10. Do you consider that this data is conclusive evidence that there is radio- active materials present in the patients examined? 11. Explain to the court the essential factors involved in the definite conclus- ions that there might be radon in the expired air? 12. Have you made gamma ray determinations of the complainants? 13. Did you find the complainants radioactive? 14. What do you consider the sensitiveness of the gamma ray method such as you employed? 15. Do you consider this method as sensitive as the method which Mrs. Hughes claims she employed? 16. Explain to the Court carefully how sensitive you consider the gamma ray instrument which you used to be? 17. Did you not hear Dr. Martland state that with the Wulf instrument which he used for his determinations he was able to detect 1/1000 of a microgram of radium el? 18. Are you familiar with the type of instrument which Dr. Martland used? 19. Do you believe this instrument to be sensitive to such a degree? 20. Are you familiar with the literature on the subject of radium? 21. Are you familiar with the literature on radium involving any hazards? 22. Are you aware that there has occurred in the literature information pointing out the hazards of handling radium compounds? 23. Are you familiar with the medical phase of the literature pretaining to radium? 24. Will you explain to the Court the general nature of the nazards involved? 25. Is it not a fact that such literature refers to comparatively large quantities of radium where deep gamma ray exposure is involved, and not to radium exposure from within the body, that is where radio-active compounds might be deposited in the bone or other organs? 26. Have you ever seen anything in the literature prior to 1925, pretaining to any dangerous effects that might result from small quantities of radium when deposited or injected into the human body? 27. You state that the knowledge you have regarding the hazards of radium involves comparatively large quantities? 28. While we recognize that you cannot definitely differentiate between large and small quantities will you please give the Court some idea from your experience, what you would consider the quantity hazardous in view of the information available in 1925? 29. Would you have been suspicious that there might have resulted injury to those engaged in the application of luminous material as practiced in our plant during the periods of 1917 - 1921? 30. Are you familiar in a general way as to what the common practice was in our plant the 31. Do you know what/basic constituents are of our luminous compound? 32. Is there anything in this compound, insofar as you knowledge was in 1925, that would have led you to believe that there might possibly have been any industrial hazard resulting from its use? material? 33. What knowledge do you have regarding the paint generally used for luminious/ 34. Is such paint essentially the same the workd over? 35. Would you have been suspicious that there would have been any more hazard in the paint manufactured by one company than by another? 36. Is it not reasonable to assume that the paint manufactured by the U.S.R.Corp., was essentially the same as that manufactured by competitive companies? 37. Is it not in your opinion a fact that the radioactive constituents contained in the paint manufactured by the U.S.R.C. are about the same preparations as used by other companies? 38. Would you consider the use of meso. in paint any more hazardous than the use of radium? 39. Explain to the Court what you mean by this statement 40. Are you thoroughly familiar with the manner in which the rays emitted from radioactive compounds will effect photographic plates? 41. What in your opinion where X-rays have been taken of any particular section or organ of the body for radium to manifest itself in the X-ray in such a manner as to definitely state that this manifestation indicated radium - assuming of course that radium was present in the organ? 42. That is if an X-ray be taken of an organ containing a small amount of radium would there be in your opinion any manifestation on this X-ray plate which could be directly ascribed to the effect of radium? 43. Did you see the dental films exhibited by Dr. Martland, showing the effects of rays claimed to be emitted by bones to which such dental films were exposed? 44. Do these films conclusively show the effects of either alpha, beta or gamma radiation? 45. Why do you make such a statement?

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    "ocrText": "Questions for direct examination of Dr. Herman Schlundt:\n1. Are you familiar with radioactive measurements?\n2. Explain to the Court what you mean by radioactive measurements?\n3. What is the difference between Emanation and gamma ray measurements?\n4. Have you made both types of measurements?\n5. Are you familiar with expired air method of making radioactive determinations\nas practiced by Mrs. Hughes?\n6. How sensitive do you consider these determinations?\n7. In other words what quantity of radium would be necessary in the body to\nproduce an appreciable count by this method?\n8. Have you examined plaintiffs by this method?\n9. Have you examined data submitted by Mrs. Hughes?\n10. Do you consider that this data is conclusive evidence that there is radio-\nactive materials present in the patients examined?\n11. Explain to the court the essential factors involved in the definite conclus-\nions that there might be radon in the expired air?\n12. Have you made gamma ray determinations of the complainants?\n13. Did you find the complainants radioactive?\n14. What do you consider the sensitiveness of the gamma ray method such as\nyou employed?\n15. Do you consider this method as sensitive as the method which Mrs. Hughes\nclaims she employed?\n16. Explain to the Court carefully how sensitive you consider the gamma ray\ninstrument which you used to be?\n17. Did you not hear Dr. Martland state that with the Wulf instrument which he used\nfor his determinations he was able to detect 1/1000 of a microgram of radium el?\n18. Are you familiar with the type of instrument which Dr. Martland used?\n19. Do you believe this instrument to be sensitive to such a degree?\n20. Are you familiar with the literature on the subject of radium?\n21. Are you familiar with the literature on radium involving any hazards?\n22. Are you aware that there has occurred in the literature information pointing\nout the hazards of handling radium compounds?\n23. Are you familiar with the medical phase of the literature pretaining to radium?\n24. Will you explain to the Court the general nature of the nazards involved?\n25. Is it not a fact that such literature refers to comparatively large quantities\nof radium where deep gamma ray exposure is involved, and not to radium exposure\nfrom within the body, that is where radio-active compounds might be deposited\nin the bone or other organs?\n26. Have you ever seen anything in the literature prior to 1925, pretaining to any\ndangerous effects that might result from small quantities of radium when\ndeposited or injected into the human body?\n27. You state that the knowledge you have regarding the hazards of radium involves\ncomparatively large quantities?\n28. While we recognize that you cannot definitely differentiate between large and\nsmall quantities will you please give the Court some idea from your experience,\nwhat you would consider the quantity hazardous in view of the information\navailable in 1925?\n29. Would you have been suspicious that there might have resulted injury to those\nengaged in the application of luminous material as practiced in our plant\nduring the periods of 1917 - 1921?\n30. Are you familiar in a general way as to what the common practice was in our plant\nthe\n31. Do you know what/basic constituents are of our luminous compound?\n32. Is there anything in this compound, insofar as you knowledge was in 1925, that\nwould have led you to believe that there might possibly have been any\nindustrial hazard resulting from its use?\nmaterial?\n33. What knowledge do you have regarding the paint generally used for luminious/\n34. Is such paint essentially the same the workd over?\n35. Would you have been suspicious that there would have been any more hazard in\nthe paint manufactured by one company than by another?\n36. Is it not reasonable to assume that the paint manufactured by the U.S.R.Corp.,\nwas essentially the same as that manufactured by competitive companies?\n37. Is it not in your opinion a fact that the radioactive constituents contained\nin the paint manufactured by the U.S.R.C. are about the same preparations\nas used by other companies?\n38. Would you consider the use of meso. in paint any more hazardous than the\nuse of radium?\n39. Explain to the Court what you mean by this statement\n40. Are you thoroughly familiar with the manner in which the rays emitted from\nradioactive compounds will effect photographic plates?\n41. What in your opinion where X-rays have been taken of any particular section\nor organ of the body for radium to manifest itself in the X-ray in such a\nmanner as to definitely state that this manifestation indicated radium -\nassuming of course that radium was present in the organ?\n42. That is if an X-ray be taken of an organ containing a small amount of radium\nwould there be in your opinion any manifestation on this X-ray plate which\ncould be directly ascribed to the effect of radium?\n43. Did you see the dental films exhibited by Dr. Martland, showing the effects of\nrays claimed to be emitted by bones to which such dental films were exposed?\n44. Do these films conclusively show the effects of either alpha, beta or gamma\nradiation?\n45. Why do you make such a statement?"
}