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{
    "localId": "75720938",
    "label": "Other, May 27, 1926",
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    "id": "75720938",
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    "contentType": "document",
    "title": "Other, May 27, 1926",
    "citationUrl": "https://catalog.archives.gov/id/75720938",
    "collections": [
        "Safety Light Collection",
        "Records Related to Radium Dial Painters"
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    "seq": 5,
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    "type": "document",
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    "ocrText": "STATE OF NEW YORK\n)\n)\nSS.\nCOUNTY OF NEW YORK\n)\nARTHUR ROEDER, being duly sworn, deposes and says:\nThat he resides at 467 Lincoln Avenue, Orange, New Jersey. That\nhe is President of the United States Radium Corporation with principal\noffices at 30 Church Street, New York City. That on May 19th, 1926,\nat about 10:35 A. M., he attended a conference in the offices of the\nsaid United States Radium Corporation at 30 Church Street, New York City.\nThat there were present at said conference, Mr. W. Redmond Cross,\nMr. Dean S. Edmonds, Mr. Joseph W. Burden, Mr. C. B. Lee, Dr.\nJoseph P. Knef, and the deponent.\nThat deponent introduced Dr. Knef to the members of the\nconference and explained that Dr. Knef had asked for the conference for\nthe purpose of making a proposition to the Directors of the said\nUnited States Radium Corporation.\nThat deponent remained during the entire conference. That\ndeponent participated in said conference and paid strict attention to\nwhat was said and done thereat and that the following is a true and\ncorrect report of the substance of what was said and done at the\nconference.\nDr. Knef opened by saying that he had come to us looking\nfor justice. That he had been to great expense of time and money\ninvestigating a disease that he called \"Radium Necrosis\" and used\nspecifically the names Carlough, Maillefer, Kuser, Maggia, saying that\nthese girls had suffered from a disease and that he had a large number\nof others that he was treating and had been treating. He produced for\nexamination X-Ray films which he stated were pictures of the jaws of some\nof the cases mentioned and of some other cases, calling particular\nattention to one strip film that he said was a case that had come in\nabout ten days before.\nHe also produced a small glass jar which he\nsaid contained a fragment of the jaw bone of one of our former\noperators.\n- 2 -\nThe early part of his statement was rambling. The principal\npoints reiterated were that if we would play ball with him he would play\nball with us. That he was a very valuable man to have with us and not\nagainst us. That the consideration was that he must be paid not only\nfor work which we would ask him to do on examinations of former employees\nbut on those that would come to him for treatment in jaw conditions.\nThat he must be paid by somebody and the class of patients that he had\nbeen treating were not able to pay adequate fees and that he must get the\nmoney out of us.\nDr. Knef was asked to state his proposition. He replied\nthat he wanted a list of all former employees and their addresses so\nthat he could get in touch with them for purposes of examination and\ntreatment. That he wanted us to pay him $10,000. which he said was\nsmall compensation for all the work that he had done on the cases that\nhe had treated since certain of them involved great effort and a large\namount of time directly with the patients as well as for research work.\nHe mentioned a treatment machine that he had designed. He said it was\na secret. He would divulge it to us if we would play ball with him.\nThe rest of his proposition was that we pay him $2.00 an office call for\nall former employees that he could get into his office. When asked if\nhe thought most of them would come to him, he said he thought it could\nbe arranged because he would speak to some of the dentists in the district\nand that they would be glad to send him any work of this kind.\nDr. Knef said that if we did not accept his proposition and\nplay ball with him, he would bring suit against certain of his former\npatients to collect large fees. That he was in a position to make any\ncharges he desired and that in turn these people would sue us for heavy\ndamages. That in that event, he was in a position to testify for them\nin such a way that he would guarantee that we would lose the suits\nbecause he could produce evidence that could not be controverted by any\nlawyers or medical experts and that he was, without blowing his own horn,\n- 3 -\nthe greatest expert in the conditions to which he referred.\nOn the other hand, if we pay him the money, he can testify\nfavorably for us. He said an expert witness's opinion was what he\nwanted it to be. That it was customary for experts to testify for the\npeople who paid them. He proposed to work for the side that his bread\nwas buttered on. He illustrated this by referring to the strip film\nmentioned above and saying, there is a case that I can say is pyorrhea\nor that it is radium necrosis. Nobody can prove otherwise, and I do\nknow the case to be tubercular. He said that he could go on the stand\nand think that the moon was made out of blue cheese without perjuring\nhimself.\nDr. Knef explained that if we did not play ball with him\nthat there were cases that would be brought against us that would not be\nsettled out of court and that there would be no Kalisches in the\nproposition. Another member of the conference asked whether his\nproposition meant in so many words that if we paid him what he asked he\ncould save us a great deal of expense and trouble and if we refused he\nwas in a position to make a lot of trouble for us and would do so.\nDr. Knef said, yes.\nDr. Knef was asked point blank whether his attitude was not\nentirely one of $10,000. plus. He replied, yes, that he must be paid,\nthat he could be a most valuable man to us from a business view point.\nOn being questioned, he explained that it was not his intention to disclose\nto any one that he had a contract or a \"gentlemen's agreement\" with the\nCompany. That he could tell his patients when they came in that they were\nsuffering from pyorrhea and other diseases and hold them along so that\nthey would move out of town, get married, and eventually die of other\ncauses. He explained that if he collected any fees from these people\nhe would credit them to the Company. He was questioned at some length\non the details of handling and explained that he was sure that he could\ncover things up and protect the Company satisfactorily. When asked\n- 4 -\nwhether any proposed arrangement with the Company should not be for\nfuture services since we had had nothing whatever to do with the past\nwork, he said that that would not be sufficient. He must have the\n$10,000. and intended to get it one way or another. One of the other\nconferees stated that we did not believe that radium had anything\nto do with the condition that he referred to. Dr. Knef said, well,\npeople can believe as they wish. That he was master of the situation\nand that he could be ferocious as a lion or as gentle as a lamb.\nTo illustrate how threatened court proceedings could be\nhandled, Dr. Knef told a story about a girl patient for whom he had\nextracted a tooth, who had gone home, and later developed a serious\nswelling in the jaw, and the girl's father threatened to bring a suit\nagainst Knef for mal-practice. He explained in some detail how a\nprofessional man must protect his reputation. He said that he had a\nletter from the father's lawyer which he ignored entirely, but met this\nlawyer on the street some time later and told him that if the suit went\non that he, Dr. Knef, knew how to protect himself. That he was\nprotected by three insurance companies, but if professional reputation\nwas at stake, he would use means for protection which he described as a\nthreat to put the girl's father and mother on the stand and embarrass\nthem by asking personal questions in regard to diseases such as\nsyphilis, and if the case went on he would break up their home.\nIn conclusion, Dr. Knef was told that his proposition was\nabsolutely immoral and that the Company would have nothing whatever to do\nwith it. Dr. Knef said, immoral is it ? Is that final ?\nSubscribed and sworn to\nbefore me this 29th day\nNOT\nof May, 1926.\na m\nOF\nPUBLIC, WESTOHESTER COUNTY\nCERTIFICATE FILED IN NEW YORK COUNTY NO. 884\nNEW YORK REGISTER'S NO. 8303\nCOMM. EXPIRES MARCH 30, 1928"
}