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    "title": "Memorandum, May 20, 1926",
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    "ocrText": "MEMORANDUM OF CONFERENCE HELD IN THE OFFICES OF\nTHE UNITED STATES RADIUM CORPORATION,\n30 CHURCH STREET,\nNEW YORK CITY,\nWEDNESDAY MAY 19, 1926, AT 10:40 TO 11:35 A. M.\nBETWEEN:\nMR. W. REDMOND CROSS\nMR. DEAN S. EDMONDS\nMR. JOSEPH W. BURDEN\nDirectors of the Corporation.\nMR. A. ROEDER\nPresident and Director of the\nCorporation.\nMR. C. B. LEE,\nTreasurer of the Corporation\nAND\nDR. JOSEPH P. KNEF OF NEWARK, N.J.\n(This is not a verbatim memorandum, but in substance\ncovers the salient points of the conference).\nAt a meeting held in Newark on May 12,\n1926, Dr. Knef having expressed a desire to make a\nproposition to our Directors, the informal conference\nwas called to hear Dr. Knef's proposition.\nDr. Knef was introduced to the three\nmembers of the conference whom he had not previously\nmet by Mr. Reeder who explained that the meeting was\ncalled to hear a proposition from Dr. Knef.\n- 2 -\nDr. Knef opened the conference by\nstating that he was coming to us looking for\njustice. He dwelt at some length on the vast\namount of research work which he had done on the\nso-called \"Radium Necrosis\" cases. He told of\nhis treatment of the Maggia girl, of the Carlough\ngirl, and Mrs. Maillefer. He said that over a\nperiod of considerable time he had treated the\nCarlough girl and called on her in Orange from two\nto six times daily. He also stated that he had\nspent as high as three days and nights at & stretch\nwith her. He also stated that he believes there are\na great many more cases coming up which may result in\nsuits against us. He further stated that through\nhis research work he had a scovered a successful\nmethod of treating these cases whereby they could be\ncarried along until they died of natural causes.\n- 3 -\nDr. Knef, without making any specific\nproposition at this point, said he came to find out\nwhether he was going to play ball with us or against\nus.\nStated he wanted to work with us if possible\nbut in any event he must be compensated for his\nservices. He explained how valuable he could be\nto us by influencing patients not to institute suits\nand also how valuable he could be as a witness.\nStated he knew more about the subject of \"Radium\nNecrosis\" than any one else. Stated that he could\ntestify to get judgments against us.\nAt this point, he exhibited a number of\nphotographs and X-Ray films of some of the girls who\nhave already died. He also exhibited X-Ray pictures\nof cases now under treatment by him. He showed\nwhat purported to be a portion of the jaw bone of the\nCarlough girl.\nThese various pictures he explained\nin some detail. He also told of the time spent in\nresearch work and in actual treatment of these cases\nand Irent reporting that he must he Days\n- 4 -\nhis services.\nHe also displayed a series of pictures\nof what he termed a new case which came to him one\nweek ago last Monday. He said that in that case\nhe could say it was either \"Radium Necrosis\" or\npyorrhea.\nHe also stated that he knew that this\nparticular patient had tubercular tendencies.\nAt this point Mr. Cross asked if he\ncould cure this case, to which Dr. Knef replied that\nhe would not guarantee a curs but he could keep the\npatient from getting worse.\nStated that he could\ndo more than any one else.\nHe suggested that he be given a list\nof the girls who had previously worked for us so that\nhe could locate them and possibly influence them to\ntake his treatment.\nStated that he was developing\na machine or method of treatment which he believed\nwould make it possible to extract some of the radium\nfrom\nthe\nbones.\nHe explained in considerable\n- 5 -\ncould testify either way. Stated his opinion\ncould be as he wished it to be at the time of\ntestifying. Stated he could testify intelligently\nwhether the case was either radium poisoning or\nphorrhea. Also said that expert witnesses always\ntestify in favor of the side that paid them.\nAfter a more or less lengthy discussion\nby Dr. Knef, Mr. Cross asked him what his proposition\nwas. Dr. Knef stated that he had proposed to us\nthat we pay him ten thousand dollars for services so\nfar rendered in treating these various cases, and that\nhe thought this was a reasonable amount.\nHe\nexplained the fairness of this charge by going into\nmore or less detail regarding the work he had done on\nthe Maggia, Carlough, and Maillefer cases, and\nreferring briefly to work done on other cases.\nStated that he is now treating a number of other cases\nand that he must be paid either by us or by some one.\nHe said he wanted to know whether he was going to play\nball for us or against us. Stated that if we were\n- 6 -\nnot interested in his proposition that he proposed\nto sue a number of his patients for large amounts\nand that he in turn would have them sue us.\nHe\nalso stated that if these suits were brought there\nwould be no settlements out of court and that there\nwould be no Kalisches in the suits. He also stated\nthat he would guarantee that we would lose these\nsuits as & result of his testimony against use\nAt this point Mr. Roeder asked Dr. Knef\nif he was a physician as well as a dentist.\nHe\nreplied no, not so far as a license was concerned.\nHe said he did not want to appear to be \"blowing his\nown horn,\" but that he knew more about medicine than\nmost doctors. He said he had studied medicine in\ncollege during his dental course and had had a practical\nexperience in hospital work for the past twenty-three\nyears. That he could passthe New York Medical Board\nexamination without doubt.\nHe also proposed that we either draw a\nformal agreement or enter into a \"gentlemen's agreement\"\n- 7 -\nto pay him for the treatment of these present cases.\nQuestioned as to what this would cost us, he stated\nthat his usual price for office calls was three dollars\nper call, plus the X-Ray pictures. That he would charge\nus but two dollars per visit, plus the X-Ray pictures,\nand would credit to us any fees which he might allect\nfrom his patients.\nThat if such an arrangement were\nentered into he would work for us in every way. Explained\nin some detail the advantages to us in having him working\nfor us and referred to an X-Ray film and told how he could\nsay if called to testify that this was an aggravated case\nof Pyorrhea, but that if he testified against us he could\nsay it was Radium Necrosis.\nThat he could think\nwhatever he wanted to on the stand and could not be\nsuccessfully controverted. Stated he had had court\nexperience as a witness. He said he could believe that\nthe moon was made of blue cheese without perjuring himself.\n- 8 -\nMr. Cross then said your attitude\nthen is based on ten thousand dollars plus other\nfinancial considerations ? Dr. Knef replied yes,\nthat his interest was on the side of the bread that\nhis butter was on. He was asked whether if we\nagreed to his proposition, would he be able to have\nall the girls come to him. He thought that he\ncould have a majority of them come to him since he was\nrecognized as an expert on this work and that he could\ngo to the various dentists in Newark, the Oranges and\nvicinity, and have them refer cases to him. He was\nthen asked if he would tell the patients that he was\nbeing paid by us for their treatment. He stated that\nif we played ball with him he would not tell them.\nThat he must be compensated. That if we did not pay him\nhe would sue some of these girls for large sums. Stated\nhe had had a great burden wished on him which was much\nlike being made an executor of an estate.\n- 9 -\nMr. Cross then asked Dr. Knef why if these\npeople owed him money it was not the proper thing for him\nto sue them.\nDr. Knef said that probably that was the\nproper procedure and that if suits in turn were brought\nagainst us that he would guarantee that they would be won.\nHe was then asked about the fee he received\nin the suits which were settled. He said he did not\nreceive nearly enough to compensate him for his services.\nHe then referred to the Maggia girl and said it was\nproblematical as to whether a suit could be brought against\nus.\nSpeaking of the Maggia girl, who died some three\nyears ago, he stated that a justice of the Supreme Court\nhad told him that he believed this case could be used as\n& basis of a suit. He said that he could get permission\nto exhume the body and that he knew that he could\nscientifically prove that Radium caused her death as he\nwould show Radium in the bones.\n1\n- 10 -\nMr. Cross then said that we had nothing\nto do with these original cases and that he did not see\nwhy we should pay the ten thousand dollars.\nAsked if\nthe ten thousand dollars was essential to Dr. Knef's\nfuture services, Dr. Knef replied yes, that he must be\ncompensated. That from a purely business point of view\nhe was a very valuable man to have with US. Mr. Cross\nthen said, the future by itself is not sufficient, you\nmust get the ten thousand dollars. Dr. Knef replied,\nyes, he must be compensated.\nHe proposed to be\nreasonable with us in the future and that he did not\nintend to gouge or bleed us.\nMr. Edmonds then referring to a series of\nX-Ray pictures, asked Dr. Knef if he were a witness and\ntestifying in a case and using that negative as a basis,\nif he could say that the picture showed either radium\nnecrosis or pyorrhea.\nDr. Knef replied that he could\nif he wanted to. That if he was working for us he would\nsay that it showed pyorrhea. That very few physicians\nwould be competent to testify on the matter and that\n- 11\nlawyers knew very little about it and that he could as\nan expert take either side and justify his position.\nHe stated he could say anything he wanted to.\nThen Dr. Knef explained in great detail\nhow a dentist must protect his reputation.\nHe\nreferred to a case where the father of a girl whom he\nhad treated proposed to bring suit. He told how he was\nprotected by three insurance companies but that he could\nnot permit his professional reputation to be attacked.\nHe told the father of the girl that if he started suit\nhe would put him on the stand, put his wife on the stand,\nask them embarrassing questions about various diseases, and\nin this way he could make it very embarrassing for the\nfather and possibly break up his home. He stated that\nhe could either be as ferocious as a lion or as gentle\nas a lamb depending on the circumstances.\nMr. Cross then said unless we pay you the\nten thousand dollars you are in a position to make a lot\n- 12 -\nof trouble for us and if we do pay you the ten\nthousand dollars you will help us.\nDr.\nKnef\nreplied, yes, that he could help us and that this\nproposition was not blackmail either. All he\nwanted was to be compensated for his services and\nthat he must be compensated. Mr. Cross then said\nthat this was something with which we had nothing\nto do. Dr. Knef replied, yes, but you may have\nsomething to do with it.\nAt this point Mr. Roeder said to Dr. Knef\nyour proposition is absolutely immoral and we will have\nnothing whatever to do with it.\nDr. Knef replied,\nimmoral, eh ? Is that answer final ?\nAt this point Dr. Knef arose, gathered up\nhis pictures and X-Ray films, and as he was leaving the\nroom said I am glad to have met you gentlemen. We will\nmeet again.\nDictated at 11 A. M. May 20, 1926 by C. B. Lee to H. Merritt\nfrom memoranda."
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