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OCR Page 1 of 3July 16,1925
Aetna Life Insurance Co.
Essex Bldg.
Newark, N.J.
Centlement
Att. Mr. Edward Breen
l'e this morning handed to you summons and complaint in
a suit, in the amount of $15,000., instituted by Theodore Kuser,
administrator of the estate of Hazel Kuser, deceased. You will
note that the alleged injuries occurred to the said Tazel Yuser
at a timo when our plant was covered by liability insurance through
your company.
Te also wish to call your attention to the fact that during
the years 1919-1920, we were known as the Radium Inminous Material
Company. Our name was changed to that of the United States Radium
Corporation in September 1921, but there was no change whatever in
ownership. through reorganizations or otherwise.
For detailed information regarding this particular claimant
whose maiden name was other than Kuser, we ask that you commicate
with r.H.V.Veidt, our rice-president, in charge of production, located
at our Orange plant. He will be able to furnish you with detailed
information. The Amorican Mutual Liability Insurance Co. also has
complete records on this individual.
In conjunction with this particular suit we wish also to state
that the American Mutual Liability Insurance Company is now defonding
a similar action brought against us several months ago. There has been
& great deal of preparatory work done on this case and we feel confident
that the American Mutual will be only too glad to give you the benefit of
investigations to date.
We have aesociated with the attorney of the Amorican Motual our
own attorneys, the firm of Lindabury, Depue & Paulks of Newark. Mr. Styykor
and Mr. Tamm of that office have been actively cooperating in the pre-
paration of the defence. We shall be very glad to have Lindabury's office
cooperate with your attorneys to the fullest extent and therefore suggest
that before filing the answer to the Kuser suit, that your counsel re-
ceive the benefit of what has been done so far. You will please note
that the expication date for the filing of the answer is July 22nd.
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