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COLLINS & CORBIN COUNSELLORS AT LAW JUN 3 1929 CLEMENT K. CORBIN ROBERT J. BAIN EDWARD A. MARKLEY CHARLES W. BROADHURST 1 EXCHANGE PLACE, HOWARD F. MC INTYRE FRANK A. BOEHLER JERSEY CITY, N.J. JAMES B. EMORY PATRICK F. MC DEVITT FRANK P. CLANCY June 1, 1929. Metz and Tuck V. U. S. Radium Corp. Burton E. Emery, Esq., Mgr., Aetna Life Ins. Co., 100 William Street, New York City. Chas. Stockdell Gray, Esq., Counsel, Globe Indemnity Co., 20 Washington Place, Newark, N. J. C. B. Lee, Esq., Pres. U. S. Radium Corp., 535 Pearl Street, New York City. Edwin F. Smith, Esq., 1 Exchange Place, Jersey City, N. J. Dear Sirs: Dr. Joseph P. Knef who is the dentist treat- ing the two plaintiffs in the above cases and who says that he in fact controls those cases, made an appointment to see me and we had a long conference yesterday, in which he did most of the talking. He is anxious to settle these cases and others that he says he has. He is particularly anxious to settle the Tuck case. He says that Mrs. Tuck will die very shortly because of radium poisoning in her system. He therefore is desirous of getting her some money to case the few remaining days of her life. Incidentally, he is very much comerned about his own compensation. Dr. Knef says he has given a great deal of time and a large amount of money to these cases for the past ten years and has practically received no compensation. He has done a great amount of research work at considerable expense for which he has received no compensation. Likewise, he has no future use for the knowledge that he thus acquired because now that the danger from rad ium poisoning is known, safeguards have been taken to guard against it, so that there vill be very few, if any, cases in the future. He said he gave a great deal #2 of his time to the five cases that we settled, but that Mr. Raymond Berry, attorney for these girls, "double-crossed" him and he received no part of the moneys paid in settlement either to the plaintiffs themselves or for medical expenses. Dr. Knef further stated that he and Dr. Flinn have been working together on the cases that are now being treated by Dr. Knef and have been recording their findings at Columbia University for future reference in the event of their death. Dr. Knef said one of their most interesting conclusions was that the children of the women who are radioactive, are also radioactive. For instance, he said he knew that both Mrs. Tuck a nd Mrs. Metz were radioactive, and that we knew it and that we merely went through the motions of having Dr. Schlundt examine these two women, so as to make it appear that we were trying to ascertain the facts. Dr. Flinn was also present at this exemination. Dr. Knef sai d the children of these women were radioactive. He had made certain tests himself which demonstrated that fact. He said that their conclusions also show that the female grandchildren of these women employees who were radioactive, would also be radioactive, but that the male grandchildren would not be. This is all recorded at Columbia University for future reference. Dr. Knef stated that Mr. Charles Weeks would do anything that he, Dr. Knef requested him to do in the way of settlement. Dr. Knef's suggestion with respect to settlement was that the United States Radium Corporat ion should take a house in the Catskills where these women could be treated and their lives made pleasent. He in- timated that he and Dr. Flinn would be willing to take the responsibility of treating these women at such a house, upon the payment of proper compensation. To this house would not only be brought the three women who have sued, but also all the other women who complain that they have radium poisoning. Dr. Knef said that the disease resulting from radium poisoning known as necrosis is absolutely in- curable. It 1s worse than leprosy. Dr. Knef would much rather have leprosy than radium poisoning. Secondly, it is Dr. Knef's suggestion that he should be given reasonable compensation by the United States Radium Corporation for all of the work that he has done as well as for the work that he will be compelled to do, in the future. Thirdly, & sum of money should be given to each of the women, although he did not name any specific sum. This seemed to be the most unimportant detail of the plan vá. th respect to compensation. #3. I informed Dr. Knef that I was not author ized to speak on the question of settlement and that anything he might say to me and that I might say to him would have to be without prejudice; the most that I could do would be to submit any proposition that he had to the companies that were interested and in due time he would receive an answer to his inquiry. I informed him, however, that I did not think the U. S. Radium Company or the insurance companies involved would be willing to maintain a house in the Catskills. Any proposition he might submit ought to be in the nature of a definite sum for each case, rather than a sum of money for himself, sums of money for the women and a house in the Catskills. He left stating that he would take the matter up with Mr. Weeks, and without prejudice to either side, he would have Mr. Weeks submit a definite concrete offer in settlement. Yours very truly, EAM: AG COLLINS & CORBIN.

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    "ocrText": "COLLINS & CORBIN\nCOUNSELLORS AT LAW\nJUN 3 1929\nCLEMENT K. CORBIN ROBERT J. BAIN\nEDWARD A. MARKLEY CHARLES W. BROADHURST\n1 EXCHANGE PLACE,\nHOWARD F. MC INTYRE FRANK A. BOEHLER\nJERSEY CITY, N.J.\nJAMES B. EMORY\nPATRICK F. MC DEVITT\nFRANK P. CLANCY\nJune 1, 1929.\nMetz and Tuck V. U. S. Radium Corp.\nBurton E. Emery, Esq.,\nMgr., Aetna Life Ins. Co.,\n100 William Street,\nNew York City.\nChas. Stockdell Gray, Esq.,\nCounsel, Globe Indemnity Co.,\n20 Washington Place,\nNewark, N. J.\nC. B. Lee, Esq.,\nPres. U. S. Radium Corp.,\n535 Pearl Street,\nNew York City.\nEdwin F. Smith, Esq.,\n1 Exchange Place,\nJersey City, N. J.\nDear Sirs:\nDr. Joseph P. Knef who is the dentist treat-\ning the two plaintiffs in the above cases and who says that he\nin fact controls those cases, made an appointment to see me\nand we had a long conference yesterday, in which he did most\nof the talking. He is anxious to settle these cases and others\nthat he says he has. He is particularly anxious to settle the\nTuck case. He says that Mrs. Tuck will die very shortly because\nof radium poisoning in her system. He therefore is desirous\nof getting her some money to case the few remaining days of\nher life.\nIncidentally, he is very much comerned about\nhis own compensation. Dr. Knef says he has given a great deal\nof time and a large amount of money to these cases for the past\nten years and has practically received no compensation. He has\ndone a great amount of research work at considerable expense\nfor which he has received no compensation. Likewise, he has\nno future use for the knowledge that he thus acquired because\nnow that the danger from rad ium poisoning is known, safeguards\nhave been taken to guard against it, so that there vill be very\nfew, if any, cases in the future. He said he gave a great deal\n#2\nof his time to the five cases that we settled, but that Mr.\nRaymond Berry, attorney for these girls, \"double-crossed\"\nhim and he received no part of the moneys paid in settlement\neither to the plaintiffs themselves or for medical expenses.\nDr. Knef further stated that he and Dr. Flinn\nhave been working together on the cases that are now being\ntreated by Dr. Knef and have been recording their findings\nat Columbia University for future reference in the event of\ntheir death. Dr. Knef said one of their most interesting\nconclusions was that the children of the women who are\nradioactive, are also radioactive. For instance, he said\nhe knew that both Mrs. Tuck a nd Mrs. Metz were radioactive,\nand that we knew it and that we merely went through the\nmotions of having Dr. Schlundt examine these two women,\nso as to make it appear that we were trying to ascertain\nthe facts. Dr. Flinn was also present at this exemination.\nDr. Knef sai d the children of these women were radioactive.\nHe had made certain tests himself which demonstrated that\nfact. He said that their conclusions also show that the\nfemale grandchildren of these women employees who were\nradioactive, would also be radioactive, but that the male\ngrandchildren would not be. This is all recorded at\nColumbia University for future reference.\nDr. Knef stated that Mr. Charles Weeks would\ndo anything that he, Dr. Knef requested him to do in the\nway of settlement. Dr. Knef's suggestion with respect to\nsettlement was that the United States Radium Corporat ion\nshould take a house in the Catskills where these women\ncould be treated and their lives made pleasent. He in-\ntimated that he and Dr. Flinn would be willing to take the\nresponsibility of treating these women at such a house,\nupon the payment of proper compensation. To this house\nwould not only be brought the three women who have sued,\nbut also all the other women who complain that they have\nradium poisoning. Dr. Knef said that the disease resulting\nfrom radium poisoning known as necrosis is absolutely in-\ncurable. It 1s worse than leprosy. Dr. Knef would much\nrather have leprosy than radium poisoning.\nSecondly, it is Dr. Knef's suggestion that he\nshould be given reasonable compensation by the United States\nRadium Corporation for all of the work that he has done as\nwell as for the work that he will be compelled to do, in the\nfuture. Thirdly, & sum of money should be given to each of\nthe women, although he did not name any specific sum. This\nseemed to be the most unimportant detail of the plan vá. th\nrespect to compensation.\n#3.\nI informed Dr. Knef that I was not author ized\nto speak on the question of settlement and that anything\nhe might say to me and that I might say to him would have\nto be without prejudice; the most that I could do would be\nto submit any proposition that he had to the companies that\nwere interested and in due time he would receive an answer\nto his inquiry. I informed him, however, that I did not\nthink the U. S. Radium Company or the insurance companies\ninvolved would be willing to maintain a house in the\nCatskills. Any proposition he might submit ought to be\nin the nature of a definite sum for each case, rather than\na sum of money for himself, sums of money for the women\nand a house in the Catskills. He left stating that he\nwould take the matter up with Mr. Weeks, and without\nprejudice to either side, he would have Mr. Weeks submit\na definite concrete offer in settlement.\nYours very truly,\nEAM: AG\nCOLLINS & CORBIN."
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