Letters Received to Chas. Stockdell Gray, April 22, 1930

COLLINS & CORBIN COUNSELLORS AT LAW CLEMENT K. CORBIN ROBERT J. BAIN 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. United States Radium Corp. Chas. Stockdell Gray, Esq., Counsel, Globe Indemni ty Co. 30 Washingtor Place, Newark, N. J. Dear Mr. Gray: We acknowledge receipt of your favor of the 15th with summons and complaint in the above together with letter of the 14th from Mr. H. H. Barker. This suit is brought in the New Jersey Supreme Court, Essex County and it is my opinion that it should not be removed to the Federal Court. This suit will not be reached for trial for over a year and a half if it is permitted to remain in the State Court, whereas if it is removed to the Federal Court it may be reached for trial within three months. We now have two cases pending in the Federal Court and we think it wise to keep the suits separated as much as possible. We have another case pending in the New Jersey Supreme Court, Essex County, namely, Madlinger V. United States Radium, but that is by Mr. Weeks, who we understand is in no way associated with Messrs. Schneider & Schneider, who bring the present action. As a matter of fact, Arthur M. Karl who appears as of couns.el with Messrs. Schneider & Schneider, is the real attorney. Apparently he felt that he could not handle the matter alone, so he brought in Messrs. Schneider & Schneider. We are writing to the United States Radium Corporation to make the usual reservation with respee to coverage. We are also going to demand a bill of particulars by making a formal motion for same and after we have fil ed answer we shall then attempt to get a testimonial examination before trial as well as a physical examination. We understand that Dr. Frederick B. Flinn of New York has already examined this waman for the purpose of determining whether she is radioactive, and we shall try to arrange with Mr. Barker to obtain whatever in- formation Dr. Flinn has. Yours very truly, EAM: AG COLLINS & C ORB IN