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EDWARD R. Mc GLYNN
COUNSELLOR AT LAW
810 BROAD STREET
NEWARK, N.J.
July 14, 1925
RECEIVED
United States Radium Corp.,
15 15 1925
50 Church St.,
Reg
New York City.
Gentlemen:
On behalf of the American Mutual
Liability Insurance Co. of Boston, I am re-
turning herewith the summons and complaint in
UNITED STATES
a suit instituted by Theodore Kuser, Admin-
istrator, etc. of the Estate of Hazel Kuser in
RADIUM M.
the New Jersey Supreme Court, Essex County Cir-
cuit, because, under the contract or contracts
of insurance between you andmy client, the
cause of action described in the complaint is
not covered by said insurance contract.
Without relying upon this particular
reason alone, I call to your attention the fact
that the complaint alleges that the said Hazel
Kuser "for several years and until July, 1920,
when she became incapacitated as hereinafter set
forth, the plaintiff's intestate was employed at
the plant of the United States Radium Corp."
My client's first insurance contract
was dated August 20, 1920 and was with the Radium
Luminous Material Corp. Therefore, as the policy
of insurance was not effective on the last day al-
leged in the complaint, my client does not feel
that it is responsible and therefore disclaims all
liability, coupled with the fact that the United
States Radium Corp. is the defendant and not the
Radium Luminous Material Corp.
The only other date mentioned in the
complaint is the date of the death of the said
Hazel Kuser, which is stated to have been December
9, 1924, and which is also, I understand, beyond
the date of the last insurance contract between
my client and the United States Radium Corp.
My client claims the benefit of all
the other provisions of its insurance contract or
contracts under the terms, conditions and covenants
of which it absolutely disclaims liability insofar
as the suit represented by the enclosed summons and
complaint is concerned.
- 2 -
United States Radium Corp. - July 14, 1925
I desire to call to your attention
the fact that the answer in this case is due on or
before July twenty third, and I would sincerely
appreciate it if you would acknowledge receipt of
this letter and enclosure.
Yours very truly,
D
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"ocrText": "EDWARD R. Mc GLYNN\nCOUNSELLOR AT LAW\n810 BROAD STREET\nNEWARK, N.J.\nJuly 14, 1925\nRECEIVED\nUnited States Radium Corp.,\n15 15 1925\n50 Church St.,\nReg\nNew York City.\nGentlemen:\nOn behalf of the American Mutual\nLiability Insurance Co. of Boston, I am re-\nturning herewith the summons and complaint in\nUNITED STATES\na suit instituted by Theodore Kuser, Admin-\nistrator, etc. of the Estate of Hazel Kuser in\nRADIUM M.\nthe New Jersey Supreme Court, Essex County Cir-\ncuit, because, under the contract or contracts\nof insurance between you andmy client, the\ncause of action described in the complaint is\nnot covered by said insurance contract.\nWithout relying upon this particular\nreason alone, I call to your attention the fact\nthat the complaint alleges that the said Hazel\nKuser \"for several years and until July, 1920,\nwhen she became incapacitated as hereinafter set\nforth, the plaintiff's intestate was employed at\nthe plant of the United States Radium Corp.\"\nMy client's first insurance contract\nwas dated August 20, 1920 and was with the Radium\nLuminous Material Corp. Therefore, as the policy\nof insurance was not effective on the last day al-\nleged in the complaint, my client does not feel\nthat it is responsible and therefore disclaims all\nliability, coupled with the fact that the United\nStates Radium Corp. is the defendant and not the\nRadium Luminous Material Corp.\nThe only other date mentioned in the\ncomplaint is the date of the death of the said\nHazel Kuser, which is stated to have been December\n9, 1924, and which is also, I understand, beyond\nthe date of the last insurance contract between\nmy client and the United States Radium Corp.\nMy client claims the benefit of all\nthe other provisions of its insurance contract or\ncontracts under the terms, conditions and covenants\nof which it absolutely disclaims liability insofar\nas the suit represented by the enclosed summons and\ncomplaint is concerned.\n- 2 -\nUnited States Radium Corp. - July 14, 1925\nI desire to call to your attention\nthe fact that the answer in this case is due on or\nbefore July twenty third, and I would sincerely\nappreciate it if you would acknowledge receipt of\nthis letter and enclosure.\nYours very truly,\nD"
}