Other, May 27, 1926

quara us aun / ) SS. COUNTY OF NEW YORK ) W. REDMOND CROSS, being duly sworn, deposes and says: That he resides at Morristown, New Jersey. That he is Chairman of the Board and a Director of the United States Radium Corporation with principal offices at 30 Church Street, New York City. That on May 19th, 1926, at about 10:40 nA. M., he attended a conference in the Directors Room of the offices of said Corporation at 30 Church Street, New York City. That there were present at said conference, Mr. Dean S. Edmonds, Mr. Joseph W. Burden, Mr. Arthur Roeder, Mr. C. B. Lee, Dr. Joseph P. Knef, and the deponent. That at the opening of the conference Mr. Roeder stated that Dr. Knef had expressed a desire to meet the Directors of the United States Radium Corporation and make them a proposition. That deponent and all of said parties to the conference of May 19th, 1926, remained during the entire conference. That deponent participated in said conference and paid strict attention to what was said and done thereat and that the following is a true and correct report of the substance of what was said and done at the conference. Dr. Knef began by stating that he was going to have justice. He said that he had done a lot of work for various patients for which he had been paid an entirely insufficient amount and that he was owed $10,000. by somebody. The question that he had come to have answered was whether the Company was going to "play ball" with him or not. He said that he knew of some necrosis cases which could be induced to bring suit against the Company for damages, but that he could probably prevent such suits being brought if we "played ball" with him. In case suits were brought, he explained that he could be of immense value to us as an expert witness and that if he testified against us, we would certainly get an adverse judgment.