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Page -8-
5.
Claims in Paragraph 5 - admitted.
6.
Cannot verify ages of complainants at the time of their employment, but assume
all were minors except one, as claimed.
(1) If important, require proof of ages.
7.
It is admitted that our officers and agents instructed the complainents to use
two kinds of binders together with thinners for the application of luminous material
to the dials of watches etc.
It must be born in mind that Sochocky was the technical director in charge of
the plant at that time, and the only officer of the Corporation who had any contact
or authority there. Further, that he was responsible for the development of both
oil and water adhesive, and the general conditions under which they were to be used.
He undoubtedly instructed those directly in charge of the application plant with
reference to these points.
Messrs. Roeder, Viedt,Lee and Dey.
8.
We deny that the oil soluble paste contained nauseating elements, but admit
that the material contained in our oil adhesive was possibly more disagreeable to the
taste than our water adhesive. We further deny that anyone who gwallowed our oll
paste would necessarily vomit. This I should say would depend entirely upon the
physicad condition of such pergon as swallowed the adhesive, together with the
quantity gwallowed.
Dr. Flinn
9.
The water soluble adhesive was not tasteless adhesive, but had a less disagreeable
taste than the oil soluble adhesive. Quantity for quantity the water adhesive
was cheaper to produce then oll - but the use of water adhesive probably cost the
corporation considerably more than if oil had been, or could have been exclusively
used.
(a) The ingredients for enough oil adhesive to paint 5000 watch dials costs
126, plus labor and overhead of manufacturing.
(b) The ingredients for enoum water adhesive to paint 5000 watch dials costs
46, plus labor and overhead of manufacturing.
Note: This is enough to supply the fastest workers for 1 month.
(c)
011 adhesive will not spoil, and will remain in its original form until
used up.
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"ocrText": "Page -8-\n5.\nClaims in Paragraph 5 - admitted.\n6.\nCannot verify ages of complainants at the time of their employment, but assume\nall were minors except one, as claimed.\n(1) If important, require proof of ages.\n7.\nIt is admitted that our officers and agents instructed the complainents to use\ntwo kinds of binders together with thinners for the application of luminous material\nto the dials of watches etc.\nIt must be born in mind that Sochocky was the technical director in charge of\nthe plant at that time, and the only officer of the Corporation who had any contact\nor authority there. Further, that he was responsible for the development of both\noil and water adhesive, and the general conditions under which they were to be used.\nHe undoubtedly instructed those directly in charge of the application plant with\nreference to these points.\nMessrs. Roeder, Viedt,Lee and Dey.\n8.\nWe deny that the oil soluble paste contained nauseating elements, but admit\nthat the material contained in our oil adhesive was possibly more disagreeable to the\ntaste than our water adhesive. We further deny that anyone who gwallowed our oll\npaste would necessarily vomit. This I should say would depend entirely upon the\nphysicad condition of such pergon as swallowed the adhesive, together with the\nquantity gwallowed.\nDr. Flinn\n9.\nThe water soluble adhesive was not tasteless adhesive, but had a less disagreeable\ntaste than the oil soluble adhesive. Quantity for quantity the water adhesive\nwas cheaper to produce then oll - but the use of water adhesive probably cost the\ncorporation considerably more than if oil had been, or could have been exclusively\nused.\n(a) The ingredients for enough oil adhesive to paint 5000 watch dials costs\n126, plus labor and overhead of manufacturing.\n(b) The ingredients for enoum water adhesive to paint 5000 watch dials costs\n46, plus labor and overhead of manufacturing.\nNote: This is enough to supply the fastest workers for 1 month.\n(c)\n011 adhesive will not spoil, and will remain in its original form until\nused up."
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