Letters Received to Mr. Smith [Edwin F. Smith], August 30, 1927

COLLINS & CORBIN COUNSELLORS AT LAW CLEMENT K. CORBIN ROBERT J. SAIN EDWARD A. MARKLEY DAVID A. NEWTON 1 EXCHANGE PLACE CHARLES w. BROADHURST JERSEY CITY. N. J. HOWARD F. MC INTYRE FRANK A. BOEHLER JAMES B. EMORY August 30, 1927. Fryer VS. U. S. Radium Corpration Mesers. Edwards & Smith, 1 Exchange Place, Oity Gentlemen: Att'n Mr. Smith Herewith enclosed find copy of petition to join parties complainant and supporting affidavits in the above which was served upon me, but not acknawledged, on August 29. I spoke to Mr. Stryker about the matter and he asked me to send you the enclosed copy 90 that you might be informed as the representative of the New Amsterdam Casualty Company of the attempt to bring in the employees whom your company covers. You will note that the motion is returnable on September 6 at Newark at 10:00 A. M. Please acknowledge receipt. We also agreed with Mr. Stryker that it would be wise to have all these claims litigated in the Court of Chanoery and that therefore perhaps we ought not to oppose this motion except on the ground that before these parties be permitted to join in the present equity suit, each should file a separate complaint setting forth the facts of each case which, of course, are lifferent in 80 far as employment, time of illness, etc., are concerned; in short, that we should not object to the joinder but that we should object to the man- ner in which the joinder of the parties is attempted and to insist upon a separate complaint being filed by each employee. Yours very truly, COLLINS & CORBIN EAM: o