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RFOD, 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