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COLLINS & CORBIN
COUNSELORS AT LAW
CLEMENT K. CORBIN
ROBERT J. BAIN
APR 23 1930
EDWARD A. MARKLEY
CHARLES w. BROADHURST
1 EXCHANGE PLACE,
HOWARD F. MC INTYRE
JERSEY CITY, N.J.
FRANK A. BOEHLER
JAMES B. EMORY
PATRICK F. MC DEVITT
FRANK P. CLANCY
JOHN F. LEONARD
April 22, 1930.
Hoare V. U. S. Radium Corp.
H. H. Barker, Esq.
Vice Pres. U. S. Radium Corp.
535 Pearl Street,
New York City.
Dear Mr. . Barker:
Herewith copy of letter to Mr. Gray in the
above which is self-explanatory.
I assume, as representing the Globe Indemni ty
Company that the usual reservation of coverage pending the de-
termination of the issues involved, is to be effected. As you
know, there are a number of questions of coverage involved,
some of which are mentioned in our letter to Mr. Lee, President
of your Company, dated November 13, 1928, in the case of Canfield,
which was the first action instituted in which the Globe appeared.
If your Company is willing that we should
assist in the defense of the action upon the ondition precedent
that in the event of a judgment going against your Company,
the Globe Indemnity Company is to have the same right to raise
the question of coverage that it would have upon the original
presentation of this claim through the Globe Indemni ty Company,
then the Globe Indemnity Company is willing to enter into the
defense and assist therein to the end that the claim may be de-
feated. In short, all that we are agreeing to do is to assist
in the defense of the case and we do not wish that action on our
part to be regarded as a waiver of any right or rights to deny
liability to you in the event that it becomes necessary to decide
that question.
Please let us have a reply to this part of
our letter as soon as practicable, saying that you are agreeable
to the arrangement herein set forth. We should also like to have
you send us as soon as practicable a complete report from Dr.
Frederick B. Flinn as to his findings in this case; also any
history that he obtained.
Yours very truly,
EAM: AG
Claring
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"ocrText": "COLLINS & CORBIN\nCOUNSELORS AT LAW\nCLEMENT K. CORBIN\nROBERT J. BAIN\nAPR 23 1930\nEDWARD A. MARKLEY\nCHARLES w. BROADHURST\n1 EXCHANGE PLACE,\nHOWARD F. MC INTYRE\nJERSEY CITY, N.J.\nFRANK A. BOEHLER\nJAMES B. EMORY\nPATRICK F. MC DEVITT\nFRANK P. CLANCY\nJOHN F. LEONARD\nApril 22, 1930.\nHoare V. U. S. Radium Corp.\nH. H. Barker, Esq.\nVice Pres. U. S. Radium Corp.\n535 Pearl Street,\nNew York City.\nDear Mr. . Barker:\nHerewith copy of letter to Mr. Gray in the\nabove which is self-explanatory.\nI assume, as representing the Globe Indemni ty\nCompany that the usual reservation of coverage pending the de-\ntermination of the issues involved, is to be effected. As you\nknow, there are a number of questions of coverage involved,\nsome of which are mentioned in our letter to Mr. Lee, President\nof your Company, dated November 13, 1928, in the case of Canfield,\nwhich was the first action instituted in which the Globe appeared.\nIf your Company is willing that we should\nassist in the defense of the action upon the ondition precedent\nthat in the event of a judgment going against your Company,\nthe Globe Indemnity Company is to have the same right to raise\nthe question of coverage that it would have upon the original\npresentation of this claim through the Globe Indemni ty Company,\nthen the Globe Indemnity Company is willing to enter into the\ndefense and assist therein to the end that the claim may be de-\nfeated. In short, all that we are agreeing to do is to assist\nin the defense of the case and we do not wish that action on our\npart to be regarded as a waiver of any right or rights to deny\nliability to you in the event that it becomes necessary to decide\nthat question.\nPlease let us have a reply to this part of\nour letter as soon as practicable, saying that you are agreeable\nto the arrangement herein set forth. We should also like to have\nyou send us as soon as practicable a complete report from Dr.\nFrederick B. Flinn as to his findings in this case; also any\nhistory that he obtained.\nYours very truly,\nEAM: AG\nClaring"
}