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DIRID U.S. DAW IORA
)
SS.
COUNTY OF NEW YORK
)
W. REDMOND CROSS, being duly sworn, deposes and says:
That he resides at Morristown, New Jersey. That he is Chairman
of the Board and a Director of the United States Radium Corporation
with principal offices at 30 Church Street, New York City.
That
on May 19th, 1926, at about 10:40 M., he attended a conference in
the Directors' Room of the offices of said Corporation at 30 Church
Street, New York City.
That there were present at said conference,
Mr. Dean S. Edmonds, Mr. Joseph W. Burden, Mr. Arthur Roeder, Mr.
C. B. Lee, Dr. Joseph P. Knef, and the deponent.
That at the opening of the conference Mr. Roeder stated that
Dr. Knef had expressed a desire to meet the Directors of the United
States Radium Corporation and make them a proposition.
That deponent and all of said parties to the conference of May 19th,
1926, remained during the entire conference. That deponent participated
in said conference and paid strict attention to what was said and done
thereat and that the following is a true and correct report of the
substance of what was said and done at the conference.
Dr. Knef began by stating that he was going to have justice.
He said that he had done a lot of work for various patients for which he
had been paid an entirely insufficient amount and that he was owed
$10,000. by somebody. The question that he had come to have answered
was whether the Company was going to "play ball" with him or not.
He
said that he knew of some necrosis cases which could be induced to bring
suit against the Company for damages, but that he could probably prevent
such suits being brought if we "played ball" with him. In case suits
were brought, he explained that he could be of immense value to us as an
expert witness and that if he testified against us, we would certainly
get an adverse judgment.
- 2 -
He then showed us some X-Ray films and picking out
one of them said that if was on our side he could testify
in Court that it was a case of pyorrhea, but that if he was
interested the other way, he could testify that it was a
clear case of radium necrosis. He said that if we would
give him a list of the girls who had worked for the Company,
he would find out if any of them were suffering from necrosis,
and if so, persuade them that they did not have any chance
to recover in case they brought suit. He stated clearly
that he would testify whichever way suited him best and stated
that this was the usual practice with expert witnesses.
I finally asked him to make a definite proposition and
he said that he would "play ball" with us if we paid him
$10,000. for work done on past cases, and in addition a reasonable
fee for cases which might come to him in the future.
I said
that I did not see why the Company should pay him for services
with which it had nothing to do. I said that the Company had
had nothing to do with his being employed on the past cases
referred to and that I did not see why the Company should pay
somebody else's bills. He said that we could suit ourselves,
but that he was going to get the money and did not care where
it came from.
He said that if new suits should be brought, he would
see to it that there were no settlements made out of Court, and
that his testimony alone would be enough to insure the verdicts
unfavorable to the Company. He said that he would make either a
contract or a gentlemen's agreement with us, whichever we wanted,
but that he must have the money.
I asked him what his charge
would be in the future, and he said $2.00 per visit, plus the
cost of the X-Ray pictures. I asked him whether he would
inform his proposed patients of the fact that he was being paid
by the Company, and he said of course not, but that he was
absolutely honest and would turn over to us any money which
he received from them.
He again said that he had to have
the money and that if we did not "play ball" with him, he would
sue his patients and have them sue us.
He said that his charges were very reasonable and that
he had no intention of gouging us, but that the $10,000. payment
was essential.
He again stated that he could testify that a
particular case was the result of pyorrhea or necrosis, and that
he could get away with anything he wanted as these things were
little understood.
He then referred to a girl who had been one of his
patients and who got paralysis of the face.
Her father
threatened to sue him, but he said that he told the father
that if he brought suit, he and his wife would be on the
stand asked whether they had ever had syphilis or gonorrhea.
He said that he told the father that he would break up his
home and that no suit was brought. He said that this would
show us that he could be as ferocious as a lion if he were
not properly treated.
I then asked him if the payment of $10,000. would
determine whether he would be for the Company or against it,
and he said that it would.
At this point Mr. Roeder stated that he thought the
proposition immoral and that the Company would have nothing to
do with it. Dr. Knef then gathered up his papers and left,
saying that we would hear from him later.
Subscribed and Sworn To
Before me this 27 day
DABIT!
of May, 1926.
Daun This
DANIEL SCHUB
NOTARY PUBLIC, KINGS COUNTY
THE
CLERK'S No. 169 REGISTER'S No. 8175
NEW YORK Co. CLERK'S No. 888 REG. No. 8684
COMMISSION EXPIRES MARCH 30, 1928
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"ocrText": "DIRID U.S. DAW IORA\n)\nSS.\nCOUNTY OF NEW YORK\n)\nW. REDMOND CROSS, being duly sworn, deposes and says:\nThat he resides at Morristown, New Jersey. That he is Chairman\nof the Board and a Director of the United States Radium Corporation\nwith principal offices at 30 Church Street, New York City.\nThat\non May 19th, 1926, at about 10:40 M., he attended a conference in\nthe Directors' Room of the offices of said Corporation at 30 Church\nStreet, New York City.\nThat there were present at said conference,\nMr. Dean S. Edmonds, Mr. Joseph W. Burden, Mr. Arthur Roeder, Mr.\nC. B. Lee, Dr. Joseph P. Knef, and the deponent.\nThat at the opening of the conference Mr. Roeder stated that\nDr. Knef had expressed a desire to meet the Directors of the United\nStates Radium Corporation and make them a proposition.\nThat deponent and all of said parties to the conference of May 19th,\n1926, remained during the entire conference. That deponent participated\nin said conference and paid strict attention to what was said and done\nthereat and that the following is a true and correct report of the\nsubstance of what was said and done at the conference.\nDr. Knef began by stating that he was going to have justice.\nHe said that he had done a lot of work for various patients for which he\nhad been paid an entirely insufficient amount and that he was owed\n$10,000. by somebody. The question that he had come to have answered\nwas whether the Company was going to \"play ball\" with him or not.\nHe\nsaid that he knew of some necrosis cases which could be induced to bring\nsuit against the Company for damages, but that he could probably prevent\nsuch suits being brought if we \"played ball\" with him. In case suits\nwere brought, he explained that he could be of immense value to us as an\nexpert witness and that if he testified against us, we would certainly\nget an adverse judgment.\n- 2 -\nHe then showed us some X-Ray films and picking out\none of them said that if was on our side he could testify\nin Court that it was a case of pyorrhea, but that if he was\ninterested the other way, he could testify that it was a\nclear case of radium necrosis. He said that if we would\ngive him a list of the girls who had worked for the Company,\nhe would find out if any of them were suffering from necrosis,\nand if so, persuade them that they did not have any chance\nto recover in case they brought suit. He stated clearly\nthat he would testify whichever way suited him best and stated\nthat this was the usual practice with expert witnesses.\nI finally asked him to make a definite proposition and\nhe said that he would \"play ball\" with us if we paid him\n$10,000. for work done on past cases, and in addition a reasonable\nfee for cases which might come to him in the future.\nI said\nthat I did not see why the Company should pay him for services\nwith which it had nothing to do. I said that the Company had\nhad nothing to do with his being employed on the past cases\nreferred to and that I did not see why the Company should pay\nsomebody else's bills. He said that we could suit ourselves,\nbut that he was going to get the money and did not care where\nit came from.\nHe said that if new suits should be brought, he would\nsee to it that there were no settlements made out of Court, and\nthat his testimony alone would be enough to insure the verdicts\nunfavorable to the Company. He said that he would make either a\ncontract or a gentlemen's agreement with us, whichever we wanted,\nbut that he must have the money.\nI asked him what his charge\nwould be in the future, and he said $2.00 per visit, plus the\ncost of the X-Ray pictures. I asked him whether he would\ninform his proposed patients of the fact that he was being paid\nby the Company, and he said of course not, but that he was\nabsolutely honest and would turn over to us any money which\nhe received from them.\nHe again said that he had to have\nthe money and that if we did not \"play ball\" with him, he would\nsue his patients and have them sue us.\nHe said that his charges were very reasonable and that\nhe had no intention of gouging us, but that the $10,000. payment\nwas essential.\nHe again stated that he could testify that a\nparticular case was the result of pyorrhea or necrosis, and that\nhe could get away with anything he wanted as these things were\nlittle understood.\nHe then referred to a girl who had been one of his\npatients and who got paralysis of the face.\nHer father\nthreatened to sue him, but he said that he told the father\nthat if he brought suit, he and his wife would be on the\nstand asked whether they had ever had syphilis or gonorrhea.\nHe said that he told the father that he would break up his\nhome and that no suit was brought. He said that this would\nshow us that he could be as ferocious as a lion if he were\nnot properly treated.\nI then asked him if the payment of $10,000. would\ndetermine whether he would be for the Company or against it,\nand he said that it would.\nAt this point Mr. Roeder stated that he thought the\nproposition immoral and that the Company would have nothing to\ndo with it. Dr. Knef then gathered up his papers and left,\nsaying that we would hear from him later.\nSubscribed and Sworn To\nBefore me this 27 day\nDABIT!\nof May, 1926.\nDaun This\nDANIEL SCHUB\nNOTARY PUBLIC, KINGS COUNTY\nTHE\nCLERK'S No. 169 REGISTER'S No. 8175\nNEW YORK Co. CLERK'S No. 888 REG. No. 8684\nCOMMISSION EXPIRES MARCH 30, 1928"
}