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ESSAMATE VA AMOUNT April 12th,1928 - at #9 Franklin St.Newark,N.J. The writer explained to Dr. S. that we were anxious to ascertain (1) whether or not plants engaged in application of luminous materials contain ing radium or radio-active constituents, used a method similar to that which we employed at our plant in Orange. That is does the general practice abroad consist of using fine camel's hair brushes for painting the numerals on watch dials, and do the operators point the brush with their lips, or did they do so at any time during the history of the industry. (2) Whether his survey brought to light any condition abroad similar to that apparently existing among our former employees. Dr. S.'s reply to the first question was that he had no knowledge. He further stated that he felt the matter of the law suits which we are defend- ing at this time was purely a personal matter between us and the plaintiffs, and he could, therefore, see no reason why he should enter into the picture in any way. He stated that he could not testify without taking sides,s to speak, and he feels that his connections with the State Department of Labor are such that he should not under any circumstances enter into this question. Dr. S. continued by saying that the information supplied him while he was abroad was strictly confidential in nature, and he felt that he would be betraying the confidence of those whom he interviewed should he disclose such information as they gave him. Dr. S. is very determined in his attitude not to become involved in these law suits, and stated that should he be called as an involuntary witness he might prove more detrimental than beneficial to us. This I attribute largely as a means of defense that Dr. S. put out to avoid our subpoenaing him as a witness. While I called to his attention the fact that Dr. McBride had been called by the plaintiffs, and that we could see no objection to his appear- ing in the case - he frankly stated that Dr. McBride was appearing much against his wishes. In the course of our conversation Dr. S. suggested that we obtain the information that he has (which frankly admitted that he knows the method employed in the painting of watch dials abroad) in the same manner as he obtained same, that is, by sending a representative abroad to interview those engaged in this line of industry. he said that he would be glad to furnish us with the names and addresses of the people whom he interviewed, and would B so far as to write these people as to who me are, and recommend that they supply us with such general information as we might desire. I told Dr. S. that we would be ver glad to get this list and he promised to send it to us. My reaction as a result of the interview with Dr. Sammalotski is that we would probably be better off not to call him as & witness, unless absolutely necessary. Dr. McBride apparently has a detailed report of Dr. S.'s survey of the situation abroad, and it is quite probable that we can obtain the informa- tion which we desire through Dr. McBride when he is placed on the witness stand by the plaintiffs. The objection to such a procedure is that we are not aware of the nature of the information which is going to develop. However, I do not see how it can prove particularly detrimental. HHBarker:RH

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    "ocrText": "ESSAMATE\nVA\nAMOUNT\nApril 12th,1928 - at #9 Franklin St.Newark,N.J.\nThe writer explained to Dr. S. that we were anxious to ascertain\n(1) whether or not plants engaged in application of luminous materials contain\ning radium or radio-active constituents, used a method similar to that\nwhich we employed at our plant in Orange. That is does the general\npractice abroad consist of using fine camel's hair brushes for painting the\nnumerals on watch dials, and do the operators point the brush with their\nlips, or did they do so at any time during the history of the industry.\n(2) Whether his survey brought to light any condition abroad similar to that\napparently existing among our former employees.\nDr. S.'s reply to the first question was that he had no knowledge.\nHe further stated that he felt the matter of the law suits which we are defend-\ning at this time was purely a personal matter between us and the plaintiffs, and\nhe could, therefore, see no reason why he should enter into the picture in any\nway. He stated that he could not testify without taking sides,s to speak,\nand he feels that his connections with the State Department of Labor are such\nthat he should not under any circumstances enter into this question. Dr. S.\ncontinued by saying that the information supplied him while he was abroad was\nstrictly confidential in nature, and he felt that he would be betraying the\nconfidence of those whom he interviewed should he disclose such information\nas they gave him.\nDr. S. is very determined in his attitude not to become involved in\nthese law suits, and stated that should he be called as an involuntary witness\nhe might prove more detrimental than beneficial to us. This I attribute\nlargely as a means of defense that Dr. S. put out to avoid our subpoenaing him as\na witness. While I called to his attention the fact that Dr. McBride had\nbeen called by the plaintiffs, and that we could see no objection to his appear-\ning in the case - he frankly stated that Dr. McBride was appearing much against\nhis wishes.\nIn the course of our conversation Dr. S. suggested that we obtain the\ninformation that he has (which frankly admitted that he knows the method\nemployed in the painting of watch dials abroad) in the same manner as he obtained\nsame, that is, by sending a representative abroad to interview those engaged in\nthis line of industry. he said that he would be glad to furnish us with the\nnames and addresses of the people whom he interviewed, and would B so far as\nto write these people as to who me are, and recommend that they supply us with\nsuch general information as we might desire. I told Dr. S. that we would be\nver glad to get this list and he promised to send it to us.\nMy reaction as a result of the interview with Dr. Sammalotski is that\nwe would probably be better off not to call him as & witness, unless absolutely\nnecessary. Dr. McBride apparently has a detailed report of Dr. S.'s survey\nof the situation abroad, and it is quite probable that we can obtain the informa-\ntion which we desire through Dr. McBride when he is placed on the witness stand\nby the plaintiffs. The objection to such a procedure is that we are not\naware of the nature of the information which is going to develop. However, I\ndo not see how it can prove particularly detrimental.\nHHBarker:RH"
}