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COLLINS & CORBIN
COUNSELLORS AT LAW
JAN 4 1929
CL
K. CORBIN
ROBERT J. BAIN
ED
4. MARKLEY
DAVID A. NEWTON
1 EXCHANGE PLACE,
HARLES w. BROADHURST
JERSEY CITY, N.J.
HOWAR
FRANK A. BOEHLER
JAMES B. EMORY
PATRICK F. MC DEVITT
January 2nd, 1929.
FRANK P. CLANCY
Re: Ethelwynne Metz (nee Peer) and Edward T. her
husband, and Helen Tuck (nee Phillips) and
W. M., her husband VS. U. S. Radium Corp.
Mr. C. B. Lee, Pres.,
U. S. Radium Corp.,
535 Pearl Street,
New York City.
Dear Mr. Lee:-
I have received a letter from Mr. Burton E.
Emory, a copy of the summons and complaint in the above
and also a letter from the Globe Indemnity Co.
Both
Companies have asked me to represent them with the usual
reservation as made in my letter to you in the Canfield
case, which letter is dated November 13, 1928.
In that letter we stated the question of
reservation as follows:-
"Reiterating my telephonic talk with you today,
please be advised that the Globe Indemnity Company
has retained me to protect its interest in the
above case.
Before we agree to undertake or assist in the
defense of this action, we must have your agreement
that all of the rights of the Globe Indemnity Com-
pany with respect to coverage of the claim presen-
ted in this action are reserved to the Globe Indemni-
ty Company pending the determination of the issues
involved in the action, There are a number of
questions of coverage involved. There is the ques-
tion whether or not proper notice of the claim was
given by your company to our company. There is also
the question whether or not the policy is broad
enough to cover a claim of the character presented.
There are also other questions of coverage.
If you and your company are willing that we
should assist in the defense of the case upon the
condition precedent that in the event of a judgment
going against your company we are to have the same
right to raise the question of coverage that we
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"ocrText": "COLLINS & CORBIN\nCOUNSELLORS AT LAW\nJAN 4 1929\nCL\nK. CORBIN\nROBERT J. BAIN\nED\n4. MARKLEY\nDAVID A. NEWTON\n1 EXCHANGE PLACE,\nHARLES w. BROADHURST\nJERSEY CITY, N.J.\nHOWAR\nFRANK A. BOEHLER\nJAMES B. EMORY\nPATRICK F. MC DEVITT\nJanuary 2nd, 1929.\nFRANK P. CLANCY\nRe: Ethelwynne Metz (nee Peer) and Edward T. her\nhusband, and Helen Tuck (nee Phillips) and\nW. M., her husband VS. U. S. Radium Corp.\nMr. C. B. Lee, Pres.,\nU. S. Radium Corp.,\n535 Pearl Street,\nNew York City.\nDear Mr. Lee:-\nI have received a letter from Mr. Burton E.\nEmory, a copy of the summons and complaint in the above\nand also a letter from the Globe Indemnity Co.\nBoth\nCompanies have asked me to represent them with the usual\nreservation as made in my letter to you in the Canfield\ncase, which letter is dated November 13, 1928.\nIn that letter we stated the question of\nreservation as follows:-\n\"Reiterating my telephonic talk with you today,\nplease be advised that the Globe Indemnity Company\nhas retained me to protect its interest in the\nabove case.\nBefore we agree to undertake or assist in the\ndefense of this action, we must have your agreement\nthat all of the rights of the Globe Indemnity Com-\npany with respect to coverage of the claim presen-\nted in this action are reserved to the Globe Indemni-\nty Company pending the determination of the issues\ninvolved in the action, There are a number of\nquestions of coverage involved. There is the ques-\ntion whether or not proper notice of the claim was\ngiven by your company to our company. There is also\nthe question whether or not the policy is broad\nenough to cover a claim of the character presented.\nThere are also other questions of coverage.\nIf you and your company are willing that we\nshould assist in the defense of the case upon the\ncondition precedent that in the event of a judgment\ngoing against your company we are to have the same\nright to raise the question of coverage that we"
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