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March 23, 1934.
Mr. Edwin F. Smith,
Edwards, Smith & Dawson,
#1 Exchange Place,
Jersey City, N.J.
Re: La Porte V. U. S. Radium Corp.
Dear Mr. Smith:
He have your letter of March 20th together
with enclosure of Answers to Interrogatories.
Interrogatory No. 3. Our records are quite
definite to the effect that nothing except radium was
used in our self luminous material prior to May 1919,
after which both radium and mesothorium in varying
quantities were used for a pierod of years,
Interrogatory No. 6. We removed our operations
from Essex Avenue, Newark, on October 1st, 1917, rather than
November 1st, and on High Street, Orange, from October 1st,
1917 thereafter.
Interrogatory No. 34. This point has probably
been covered about as well as it would be possible to do.
While we might speculate as to precautions given, particular-
ly from a sanitary standpoint, still we are not able to back
up such instructions unless through the testimony of in-
structors or people in charge of the application plant, some
of whom are on our list of possible witnesses to be inter-
viewed prior to the trial set for June 4th, 1934.
Very truly yours,
HHBarker:DK
Vice-President
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"ocrText": "March 23, 1934.\nMr. Edwin F. Smith,\nEdwards, Smith & Dawson,\n#1 Exchange Place,\nJersey City, N.J.\nRe: La Porte V. U. S. Radium Corp.\nDear Mr. Smith:\nHe have your letter of March 20th together\nwith enclosure of Answers to Interrogatories.\nInterrogatory No. 3. Our records are quite\ndefinite to the effect that nothing except radium was\nused in our self luminous material prior to May 1919,\nafter which both radium and mesothorium in varying\nquantities were used for a pierod of years,\nInterrogatory No. 6. We removed our operations\nfrom Essex Avenue, Newark, on October 1st, 1917, rather than\nNovember 1st, and on High Street, Orange, from October 1st,\n1917 thereafter.\nInterrogatory No. 34. This point has probably\nbeen covered about as well as it would be possible to do.\nWhile we might speculate as to precautions given, particular-\nly from a sanitary standpoint, still we are not able to back\nup such instructions unless through the testimony of in-\nstructors or people in charge of the application plant, some\nof whom are on our list of possible witnesses to be inter-\nviewed prior to the trial set for June 4th, 1934.\nVery truly yours,\nHHBarker:DK\nVice-President"
}