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May 22, 1925. Mr. W. H. B. Dumont, c/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 she 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 American Mutual Insurance Company, Newark Branch, with the assistance of our counsel, Lindabury, Depue & Faulks of Newark. While 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 Factory 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-HM

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    "ocrText": "May 22, 1925.\nMr. W. H. B. Dumont,\nc/o Waterbury Clock Company,\n30 Irving Place,\nNew York City.\nDear Mr. Dumont:\nI am following your suggestion and confirming with\nthis note, points of our conference yesterday.\nOne of the former operators in our Application Plant\nin Orange, N. J. has brought suit against us claiming that a jaw\nnecrosis from which she is and has been suffering was caused by Radium\npoisoning. Since the State Compensation Board denied compensation\nin the case, the complaint is brought on the ground of negligence.\nWe are at present organizing a defense which is to be\nhandled by the American Mutual Insurance Company, Newark Branch, with\nthe assistance of our counsel, Lindabury, Depue & Faulks of Newark.\nWhile the defense will be largely technical and medical and special\nevidence, one phase of it will be experience in other plants doing\nsimilar work. You will oblige me greatly if you will inquire at your\nFactory in Waterbury whether they have ever heard of a similar condition\nand whether they would be willing to give us the assistance of some\nman who has been associated with your department for a good period of\ntime and could testify that the conditions in Waterbury have been\nentirely satisfactory.\nCordially,\nPresident.\nARoeder-HM"
}