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REOD
Edwin T. Smith
OCT 20 1927
Raymond Dawson
Edwards & Smith
Attorneys Counsellors at Law
RADIUM 14-18002
No.1 Exchange Place
Telephone 2037 2035 2036 Montgomery
CORP.
Jersey City.N.J. N.J.
October 19, 1927.
United States Radium Corp.,
535 Pearl Street,
New York City.
Att: Mr. Lee.
Re: McDonald VS. United States Radium Corp.
My dear Sir:
In the Bill of Complaint filed by Mr.
Berry in the above entitled matter, he annexed thereto
Interrogatories as follows:
"FIRST INTERROGATORY: What steps were taken
by the United States Radium Corporation or any
of its officers and agents to investigate the
condition of health of its employees, prior to
the investigation made by Doctor Drinker?
"SECOND INTERROGATORY: Did the United States
Radium Corporation or any of its officers and
agents pay Doctor Frederick B. Flinn for the in-
vestigation of effect, if any, on the human
system of luminous paint manufactured and used
by the defendant, which investigation by Doctor
Flinn was requested by the defendant?
"THIRD INTERROGATORY: Who was or were the
Head or Heads of the Physical, Chemical and
Medical Departments of the United States Radium
Corporation during the years 1917 and 1925?
"FOURTH INTERROGATORY: Who were the assist-
ants of those Heads of Departments during the
period of time from the years 1917 to 1925?"
It may be necessary for us to answer these,
although I have declined to do so at the present time.
Will you please, however, look up the information and
let me have it as speedily as possible?
Very truly yours,
EFS/RH
Edwin 7 Smith
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"ocrText": "REOD\nEdwin T. Smith\nOCT 20 1927\nRaymond Dawson\nEdwards & Smith\nAttorneys Counsellors at Law\nRADIUM 14-18002\nNo.1 Exchange Place\nTelephone 2037 2035 2036 Montgomery\nCORP.\nJersey City.N.J. N.J.\nOctober 19, 1927.\nUnited States Radium Corp.,\n535 Pearl Street,\nNew York City.\nAtt: Mr. Lee.\nRe: McDonald VS. United States Radium Corp.\nMy dear Sir:\nIn the Bill of Complaint filed by Mr.\nBerry in the above entitled matter, he annexed thereto\nInterrogatories as follows:\n\"FIRST INTERROGATORY: What steps were taken\nby the United States Radium Corporation or any\nof its officers and agents to investigate the\ncondition of health of its employees, prior to\nthe investigation made by Doctor Drinker?\n\"SECOND INTERROGATORY: Did the United States\nRadium Corporation or any of its officers and\nagents pay Doctor Frederick B. Flinn for the in-\nvestigation of effect, if any, on the human\nsystem of luminous paint manufactured and used\nby the defendant, which investigation by Doctor\nFlinn was requested by the defendant?\n\"THIRD INTERROGATORY: Who was or were the\nHead or Heads of the Physical, Chemical and\nMedical Departments of the United States Radium\nCorporation during the years 1917 and 1925?\n\"FOURTH INTERROGATORY: Who were the assist-\nants of those Heads of Departments during the\nperiod of time from the years 1917 to 1925?\"\nIt may be necessary for us to answer these,\nalthough I have declined to do so at the present time.\nWill you please, however, look up the information and\nlet me have it as speedily as possible?\nVery truly yours,\nEFS/RH\nEdwin 7 Smith"
}