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COLLINS & CORBIN COUNSELLORS AT LAW CLEMENT K. CORBIN ROBERT J. BAIN EDWARD A. MARKLEY CHARLES w. BROADHURST 1 EXCHANGE PLACE, JERSEY CITY, N. J. HOWARD F. MC INTYRE FRANK A. BOEHLER JAMES B. EMORY PATRICK F. MC DEVITT FRANK P. CLANCY June 6, 1929. Canfield V. U. S. Radium Corp. Messrs. Potter & Berry, 60 Park Place, Newark, N. J. Dear Sirs: Your representative this morning handed to me in the above case a stipulation for the taking of the testinony of Dr. Krumbhaar, Dr. Janes Ewing, Dr. Lloyd F. Craver and Dr. Fialla, such testimony to be taken on the 27th instent at two o'clook in the afternoon at the office of Messrs. Miller & Chevalier, 111 Broadway, New York City, be- fore Nicholas Bindseil. We have no objection to the time and place, provided the stipulation is so drawn as to clearly indicate: 1. That you are taking the testimony of these men as your witnesses. 2. That the testimony is being taken de bene essy that is, that it is to be taken and is to be used only in the event that the itnesses cannot be produced at the trial. 3. That we are to have the right to oross exemine the witnesses. 4. We are to have the right to use the testimony on the trial in the event that you do not do so, if we in our judgment feel that we want to read it into the record. 5. We are to receive a gopy of the testimony at your expense. As the stipulation is now drawn, it would apre ar as though these witnesses were being called by both sides and that we and you together were taking the testimony, whereas the faot is that they are appearing as your witnesses in this pro- ceeding and you are galling them to substantiate the allegations contained in your complaint. Yours very truly, EAMIAG Coun Corona