Letters Received to Chas. Stockdell Gray, April 23, 1931

COLLINS & CORBIN COUNSELLORS AT LAW CLEMENT K. COREIN ROBERT J. BAIN EDWARD A. MARKLEY CHARLES w. BROADHURST 1 EXCHANGE PLACE, HOWARD F. MC INTYRE JAMES B. EMORY FRANK A. BOEHLER JERSEY CITY. N.J. APR 24 1931 PATRICK F. MC DEVITT JOHN F. LEONARD JOHN P. GILMARTIN April 23, 1931. Hoare V. U. S. Radium Corp. Chas. Stockdell Gray, Esq., Counsel, Globe Indemnity Co. 20 Washington Place, Newark, N. J. Dear Mr. Gray: In the above case we have had a number of conferences with Mr. Jacob Schneider, the attorney for the plaintiff, the last one on April 22, 1931. Mr. Schneider, as we formerly advised you is willing to settle for $10,000. We told him there was no chance of settlement on that basis be- cause according to investigation the plaintiff was not radio- active. We informed him that Drs. Schlundt, Flinn, Brothers and Humphries had all concluded that this was not a true radium case. Also we told him that the statute of limitations was a strong defense here because the plaintiff had admittedly suffered for at least three years before the suit was brought. We think that Mr. Cohneider was duly im- pressed with the fact that the probability of settlement of this case was doubtful. He wanted to know whether our company would consider payment of $3000. I told him that I did not know, but ir he wished to make such an offer I would submi t it. He will take the matter up with his client and let us hear from him later. In this case we feel that a settlement for $3000. would probably be wise, everything consi dered. Please let us have your instructions. We are sending copy of this letter to Mr. Lee, President of the U. S. Radium Corporation. or course, any settlement that might be made by you would be subject to your reservation of rights heretofore made. Your company is the only company on this risk. Neither the Aetna nor the New Amsterdam have any coverage. Yours very truly, EAM: AG COLLINS & CORBIN.