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FREDERIC J. FAULKS
LINDABURY, DEPUE & FAULKS
J. EDWARD ASHMEAD
JOSIAH STRYKER
JOHN W. BISHOP, JR.
PRUDENTIAL BUILDING
WALTER D. BARKER
TELEPHONE
JAMES E. M.TAMS
MULBERRY 1755
BURTIS S. HORNER
763 BROAD street, newark N.J.
ALAN W. CARRICK
EDWARD P. O'NEILL, JR.
March 12, 1928.
RE: FREYER VS. U.S. RADIUM CORP. #3486-LDF
19 81 87W
THIS
C. B. Lee, President,
U.S. Radium Corporation,
535 Pearl St.,
New York City.
Dear Mr. Lee,
I have your letter of the 10th inst. I think it
would be well to have Dr. Schlundt as a witness, although I
think there will be some uncertainty as to the benefit which
we will receive from the testimony of any of these experts
until after we have had an opportunity to discuss the matter
with them in some detail.
If they will testify that prior
to 1924 there was no reason to suppose that the use of the
paint as used in your plant would cause trouble to the em-
ployees that will be very helpful to us.
If they can go
farther and say that even after Dr. Drinker's report was
made there was still grave doubt as to whether he was not
mistaken that will also be helpful.
The thing that I particularly wish to learn from
an interview with these men is as to how many qualifications
they will impose on those two statements for I fear that
they may so qualify them as to make their testimony as of
little use to us.
Yours very truly,
JS/EAS
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"ocrText": "FREDERIC J. FAULKS\nLINDABURY, DEPUE & FAULKS\nJ. EDWARD ASHMEAD\nJOSIAH STRYKER\nJOHN W. BISHOP, JR.\nPRUDENTIAL BUILDING\nWALTER D. BARKER\nTELEPHONE\nJAMES E. M.TAMS\nMULBERRY 1755\nBURTIS S. HORNER\n763 BROAD street, newark N.J.\nALAN W. CARRICK\nEDWARD P. O'NEILL, JR.\nMarch 12, 1928.\nRE: FREYER VS. U.S. RADIUM CORP. #3486-LDF\n19 81 87W\nTHIS\nC. B. Lee, President,\nU.S. Radium Corporation,\n535 Pearl St.,\nNew York City.\nDear Mr. Lee,\nI have your letter of the 10th inst. I think it\nwould be well to have Dr. Schlundt as a witness, although I\nthink there will be some uncertainty as to the benefit which\nwe will receive from the testimony of any of these experts\nuntil after we have had an opportunity to discuss the matter\nwith them in some detail.\nIf they will testify that prior\nto 1924 there was no reason to suppose that the use of the\npaint as used in your plant would cause trouble to the em-\nployees that will be very helpful to us.\nIf they can go\nfarther and say that even after Dr. Drinker's report was\nmade there was still grave doubt as to whether he was not\nmistaken that will also be helpful.\nThe thing that I particularly wish to learn from\nan interview with these men is as to how many qualifications\nthey will impose on those two statements for I fear that\nthey may so qualify them as to make their testimony as of\nlittle use to us.\nYours very truly,\nJS/EAS"
}