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OCR Page 1 of 2May 22, 1925.
Mr. W. H. B. Dumont,
e/o Waterbury Clock Company,
30 Irving Place,
New York City.
Dear Mr. Dumont:
I am following your suggestion and confirming with
this note, points of our conference yesterday.
One of the former operators in our Application Plant
in Orange, N. J. has brought suit against us claiming that a jaw
necrosis from which the is and has been suffering was caused by Radium
poisoning. Since the State Compensation Board denied compensation
in the case, the complaint is brought on the ground of negligence.
We are at present organizing a defense which is to be
handled by the "merican Mutual Insurance Company, Newark Branch, with
the assistance of our counsel, Landabury, Depue & Faulits of Newark
lihile the defense will be largely technical and medical and special
evidence, one phase of it will be experience in other plants doing
similar work. You will oblige me greatly if you will inquire at your
Pactory in Waterbury whether they have ever heard of a similar condition
and whether they would be willing to give us the assistance of some
man who has been associated with your department for a good period of
time and could testify that the conditions in Waterbury have been
entirely satisfactory.
Cordially,
President.
ARoeder-EDI
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