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February 16,1928.
Aetna Life Insurance Co.,
100 William Street,
New York City.
Attention: Mr. Emory
Dear Mr. Emory:
In compliance with your request we give you herewith information
the dates of employment of the five (5) girls
against us suits for damages:
GRACE FRYER - Complaint states employment was from Feb. 1,1917 to July 1,1920,
and from Nov. 27,1920 to June 7,1922. We do not believe these dates are
correct and have not admitted them in our answer. Our employment records show
that Miss Fryer was employed from Dec. 26,1918 to March 19,1920. There is a
question of fact here as to employment which will undoubtedly be settled if
the case is ever prosecuted through trial to a conclusion.
EDNA HUSSMAN - Complaint states that employment was from June 1,1917 to February
1921. These dates check with those on our employment records.
KATHERINE SCHAUB - Complaint states that employment was from February 1917 to
July 1920, and from Nov. 27,1920 to June 7,1922. Our Employment records show
that she was employed from March 22,1917 to March 19,1920. Here is another
question of fact which must be determined by trial.
MRS. MCDONALD - Complaint states she was employed from March 1,1917 to Feb.1,
1919. These dates substantially check with our employment records.
MRS. LARICE - Complaint states she was employed from August 1917 to June 1,
1919. These datës substantially check with our employment records.
Our employment records are not as complete as they might be,
and there is a possibility that we may be in error, and that the dates claimed
in the complaints are substantially correct, even though we have denied them in
the answer.
Naturally the question as to the portion of the expense of the
defense which you are willing to assume, is a vital one to us, but we are will-
ing to leave the matter to your good judgment and fairness. The fact that
there are five suits instituted against us does not mean that we will spend
anymore on defense than if there were but one suit. The chief consideration
for the moment is the perfecting of a successful defense, and it is gratifying
to know that your Company is willing to assume its equitable proportion of the
financial burden.
Trusting that the above information gives you what you want, we are
Very truly yours,
CBLee:RH
President.
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"ocrText": "February 16,1928.\nAetna Life Insurance Co.,\n100 William Street,\nNew York City.\nAttention: Mr. Emory\nDear Mr. Emory:\nIn compliance with your request we give you herewith information\nthe dates of employment of the five (5) girls\nagainst us suits for damages:\nGRACE FRYER - Complaint states employment was from Feb. 1,1917 to July 1,1920,\nand from Nov. 27,1920 to June 7,1922. We do not believe these dates are\ncorrect and have not admitted them in our answer. Our employment records show\nthat Miss Fryer was employed from Dec. 26,1918 to March 19,1920. There is a\nquestion of fact here as to employment which will undoubtedly be settled if\nthe case is ever prosecuted through trial to a conclusion.\nEDNA HUSSMAN - Complaint states that employment was from June 1,1917 to February\n1921. These dates check with those on our employment records.\nKATHERINE SCHAUB - Complaint states that employment was from February 1917 to\nJuly 1920, and from Nov. 27,1920 to June 7,1922. Our Employment records show\nthat she was employed from March 22,1917 to March 19,1920. Here is another\nquestion of fact which must be determined by trial.\nMRS. MCDONALD - Complaint states she was employed from March 1,1917 to Feb.1,\n1919. These dates substantially check with our employment records.\nMRS. LARICE - Complaint states she was employed from August 1917 to June 1,\n1919. These datës substantially check with our employment records.\nOur employment records are not as complete as they might be,\nand there is a possibility that we may be in error, and that the dates claimed\nin the complaints are substantially correct, even though we have denied them in\nthe answer.\nNaturally the question as to the portion of the expense of the\ndefense which you are willing to assume, is a vital one to us, but we are will-\ning to leave the matter to your good judgment and fairness. The fact that\nthere are five suits instituted against us does not mean that we will spend\nanymore on defense than if there were but one suit. The chief consideration\nfor the moment is the perfecting of a successful defense, and it is gratifying\nto know that your Company is willing to assume its equitable proportion of the\nfinancial burden.\nTrusting that the above information gives you what you want, we are\nVery truly yours,\nCBLee:RH\nPresident."
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