Letters Received to Chas. Stockdell Gray, June 28, 1930

OLLINS & 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 June 28, 1930. Hoare V. Uni ted States Radium Corp. Chas. Stockdell Gray, Esqo, Globe Indemni ty Co. 20 Washington Place, Newark, N. J. Dear Mr. Gray: I have examined Dr. Brothers' report as well as the history of the case that he obtained stenographic- ally. It appears from the history that the plaintiff has been suffering for more than three and a half years from her teeth along and that she has had trouble ever since she left our plant, of which she complained. If that is so, the statute of limitations clearly has run against this claim. The only answer that could be made to our contention that the statute has run, is that she did not know that she had radium poison- ing, but whether she knew it or not would seem to be immaterial under most of the decisions, provided she had actual injury resulting from her employment in our plant. She worked for us for about six months in 1916-1917, so that over thirteen years have passed since her last employment. It is therefore important to have a special investigation made to obtain from Mrs. Hoare the various ail- ments that she has had and the troubles that she suffered from beginning in 1916 and 1917 to date. Also it is very important to ascertain the doctors and dentists who have treated her during the period following her employment with our company. If your company can make this investigation by its own in- vestigators, perhaps we should do it that way. On the other hand, if you feel you cannot get the information through your own investigation, we suggest the employment of Miss Lewis to make an investigation for us. This case is covered merely by your company and no other insurance company is involved. I do not under- stand with respect to such a case that the disbursements are to be made out of the general disbursement fund, which in any event has been exhausted so far as the present funds are concerned. It may be well at this time for you to call a conference of all of the companies interested, for the purpose of settling the various questions W hich have arisen with respect