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    "localId": "75728200",
    "label": "Letters Received to C.B. Lee, August 28, 1934",
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    "title": "Letters Received to C.B. Lee, August 28, 1934",
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    "collections": [
        "Safety Light Collection",
        "Records Related to Radium Dial Painters"
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    "seq": 2,
    "pageIndex": 0,
    "type": "document",
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    "ocrText": "COLLINS & CORBIN\nCOUNSELLORS AT LAW\nCLEMENT K. CORBIN\nROBERT J. BAIN\nEDWARD A. MARKLEY\nCHARLES W. BROADHURST\n1 EXCHANGE PLACE,\nHOWARD F. MC INTYRE JAMES B. EMORY\nJERSEY CITY, N.J.\nPATRICK F. MC DEVITT\nJOHN F. LEONARD\nJAMES J. LANGAN\nADOLPH S. HUMMEL\nCHARLES H. SCHAFER\nENOS A. PYLE\nRAYMOND J. LAMB\nEARLE J. HARRINGTON\nAugust 28, 1934.\nRE: Sullivan VS. United States Radium\nCorporation.\nC. B. Lee, Esq.,\nPresident, United States Radium Corp.,\n535 Pearl Street,\nNew York City\nDear Mr. Lee:-\nThe above case is one in which we\nare appearing for your company as per your letter of April\n13th, 1934. We have been having proceedings in court with\nrespect to obtaining from the plaintiff as complete a bill\nof particulars as practicable. We have now reached the\npoint where we are about to file answer. I am also request-\ning from our adversary physical examinations, including an\nx-ray examination. These, we are undoubtedly entitled to,\nand if they are refused we will have to go into court and\nobtain an order compelling them. I am also going to try\nto obtain a testimonial examination before trial. In order\nto obtain that it is necessary to obtain the consent of\nour adversary since we are not entitled to it as a matter\nof right.\nIt has also occurred to me that it\nmight be wise to have a special investigator check up on\nthe plaintiff for the purpose of ascertaining her present\nactivities, including her employment, her health, her home\nlife, etc. We had a detective by the name of William\nMcCarthy do some of this work for us before although I\nthink he is too expensive to use as he charges $20.00 per\nday plus expenses. We could probably get a Pinkerton de-\ntective for $10.00 a day. On the other hand, I think per-\nhaps an ordinary investigator who investigates cases of this\ntype for insurance companies might be the best kind of a man\nto have.\nI suggest that we have a conference\nat your earliest convenience for the purpose of deciding\njust how far we should go in the preparation of the case.\nAUG 29 1934\nWith kindest regards,\nSincerely yours,\nEAM:LB\nTamaklass"
}