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OCR Page 1 of 2RFOD,
Odwin T.Smith
OCT 201927
Raymond Dawson
I
Edwards & milh
A
at Law
No.1 Exchange Place
2035
Telephone 2036
Montgomeng
Jersey City N.J.
2037
October 19, 1927.
United States Radium Corp.
535 Pearl street,
New York City.
Att: Mr. Lee.
Re: McDonald vs. United states Radium corp.
My dear Sir:
In the Bill of Complaint filed by Mr.
Berry in the above entitled matter, he annexed thereto
Interrogatories as follows:
"FIRST INTERROGATORY: What steps were taken
by the United States Radium Corporation or any
of its officers and agents to investigate the
condition of health of its employees, prior to
the investigation made by Doctor Drinker?
"SECOND INTERROGATORY: Did the United States
Radium Corporation or any of its officers and
agents pay Doctor Frederick B. Flinn for the in-
vestigation of effect, if any, on the human
system of luminous paint manufactured and used
by the defendant, which investigation by Doctor
Flinn was requested by the defendant?
"THIRD INTERROGATORY: Who was or were the
Head or Heads of the Physical, Chemical and
Medical Departments of the United States Radium
Corporation during the years 1917 and 1925?
"FOURTH ENTERROGATORY: Who were the assist-
ants of those Heads of Departments during the
period of time from the years 1917 to 1925?"
It may be necessary for us to answer these,
although I have declined to do so at the present time.
Will you please, however, look up the information and
let me have it as speedily as possible?
Very truly yours,
EFS/RH
Edwin 7 mith
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