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    "title": "Letters Received to C.B. Lee, Chas. Stockdell Gray, January 26, 1932",
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        "Safety Light Collection",
        "Records Related to Radium Dial Painters"
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    "seq": 3,
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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\nJOHN P. GILMARTIN\nJAMES J. LANGAN\nJanuary 26, 1932.\nHoare V. U. S. Radium Corp.\nC. B. Lee, Esq.,\nPres. U. S. Radium Corp.\n535 Pearl Street,\nNew York City.\nChas. Stockdell Gray, Esq.,\nCounsel, Globe Indemnity Co.\n20 Washington Place,\nNewark, N. J.\nGentlemen:\nThe motion to advance the trial of the above\naction was argued before Judge Dungan at the Supreme Court,\nNewark, on January 22, 1932. We succeeded in having the motion\nto advance the case denied.\nHowever, we call your attention to the fact\nthat this case is No. 1637 on the trial calendar for the\nDecember term, 1931 and that the court is now down to approxi-\nmately case No. 500; that there are four judges hearing cases\nin Essex County. If we divide the remaining 1200 cases\napproximately, between the four judges, it means that each\njudge will have 250 cases. At the rate the judges are pro-\nceeding this case ought to be reached for trial before July\n1st of this year when the Summer vacation sets in, so that\nif the case is to be contested, steps should now be taken\nto prepare it for trial.\nThe only insurance company on this case is\nthe Globe Indemnity Company. The plaintiff is now asking\n$5000. in settlement. We do not think that this is the lowest\nfigure. We think it can be settled as low as $3000. We\nrecommend settlement for 3000. if better terms cannot be\nsecured. We make such recommendation notwithstanding that\nthe defense of the statute of limitations is fairly strong.\nDr. Schlundt has found the plaintiff slightly radio-active;\nso has Dr. Flinn who in this case represents the plaintiff and\nher attorney, Mr. Carl and counsel, Mr. Schneider. The latter\nis an experienced trial lawyer in negligence cases and will\nmake the most of Dr. Flinn's testimony.\nHowever, our recommendation to pay $3000. is\nbased primarily on the fact that it will cost us $3000. or\nC. B. Lee, Esq.,\nChas. Stockdell Gray, Esq\n#2\nmore to contest this case. The plaintiff has become obstreperous\nand has been going directly to the judges of the court and com-\nplaining about her lawyers. Those complaints brought about the\nmotion to advance the trial. The lawyers are on their metal\nand will have to present the case when it is reached for trial.\nWe will have to have as experts Drs. Herman\nSchlundt of Columbia, Missouri, Robert E. Humphries, James\nH. Brothers, Harrison S. Martland, Dr. Linn, Dr. Lloyd F.\nCraver, and probably twenty or more lay witnesses. In our\nletter to Mr. Gray of April 23, 1931, we stated that a settle-\nment for $3000. probably would be wise, everything considered\nand we asked for instructions. Mr. Gray replied under date of\nApril 28, 1931 that so far as the Globe Indemnity was concerned,\nit would authorize the United States Radium Corporation to make\na settlement up to $1800. The case cannot be settled for\n$1800. and it cannot be settled so far as we believe, for any-\nthing less than $3000. If it is to be settled, now is the time\nto settle it. If it is not to be settled, we should begin to\nprepare it for trial for as stated above, the trial will be\nreached sometime before July 1st and it is quite probable\nthat trial will be reached in the ordinary course by April 1st\nor May 1st, all depending on how long the cases ahead will take.\nWe promised to give Mr. Schneider a definite\nanswer as to settlement by Saturday of this week and we would\ntherefore appreciate it if you would let us know before Satur-\nday what your instructions are in the premises. If settlement\nis not to be authorized, then Mr. Lee should confer with us\nfor the purpose of preparing answers to the interrogatories\nwhich were heretofore served.\nYours very truly,\nEAM: AG\nColluis acorhing"
}