Letters Received, July 14, 1925

EDWARD R. MC GLYNN COUNSELLOR AT LAW 810 BROAD STREET NEWARK, N.J. July 14, 1925 REOFIVED United States Radium Corp , 50 Church St. Reg mark 15 1925 New York City. a Gentlemen: S On behalf of the American Mutual Liability Insurance Co. of Boston, I am re- turning herewith the summons and complaint in UNITES STACK a suit instituted by Theodore Kuser, Admin- istrator, etc. of the Estate of Hazel Kuser in the New Jersey Supreme Court, Essex County Cir- cuit, because, under the contract or contracts of insurance between you andmy client, the cause of action described in the complaint is not covered by said insurance contract. Without relying upon this particular reason alone, I call to your attention the fact that t the complaint alleges that the said Hazel Kuser "for several years and until July, 1920, when she became incapacitated as hereinafter set forth, the plaintiff' intestate was employed at the plant of the United States Radium Corp." My client's first insurance contract was dated August 20, 1920 and was with the Radium Luminous Material Corp. Therefore, as the policy of insurance was not effective on the last day al- leged in the complaint, my client does not feel that it is responsible and therefore disclaims all liability, coupled with the fact that the United States Radium Corp. is the defendant and not the Radium Luminous Material Corp. The only other date mentioned in the complaint is the date of the death of the said Hazel Kuser, which is stated to have been December 9, 1924, and which is also, I understand, beyond the date of the last insurance contract between my client and the United States Radium Corp. my client claims the benefit of all the other provisions of its insurance contract or contracts under the terms, conditions and vovenants of which it absolutely disclaims liability insofar as the suit represented by the enclosed summons and complaint is concerned.