Letters Received to C.B. Lee, Josiah Stryker, [Edwin F. Smith], August 29, 1927

COLLINS a CORBIN COUNHELLORS - - . 1 EXCHANGE PLACE - JERSEY CITY. N. J. - - . BODILER - August 29, 1927. Messrs. Edwards & Smith, 1 Exchange Place, Jersey Gity, N.J. Josish Stryker, Esge, e/o Lindabury, Dejue & Faulks, Prudential Blage, Newark, H. J. C. B. Lee, Esq., Pres't, U. S. Radium Corporation, 535 Pearl Street, New York city. Gentlemen: Herewith enclosed find copy of finel draft of answer in the above to the bill of complaint in the equity quit. Upon reflection, it sogma unnecessary to me to set forth in narrative form lefense begause it is ad- missible by way of denial allegatione of the com- plaint. It is my understanding that laches does not have to be pleaded except in terms and I have so pleaded it. I also thought it wise to answer that upon the face of the bill there appeared no equity. That is really the fact if the casea in New Jersey are to be followed, an by the cases in New Jersey I refer to such cases as lamb vs. Martin, 43 N. J. Eq. 34; Clark V8. Augustine, 62 N. J. Eq. 689; and Freeman vs. Conover, 95 N. J. Le 89, 94. Next to the answer will be found the mewers to the interrogatories. The ansuer must be filed on September 1 at Trenton and I would therefore appreciate advices from all.of you as to whether the answer meets with your approval as it is non drawn, and if 80, I chould like to have Mr. Lee oall for the purpose of executing the:answers to interrogatories on Tuesday, August 30, at 2:00 P. M. Yours very truly, EAM: o Edward a markley