Document DMJ6QRL2XQKNzYQO61aLXMzoa

EMIL J. VERLIE. 1891*1940 C. DANA EASTMAN J . F. SCHLAFLY.JR. EMERSON BAETZ JOHN J. GAINER VER LIE. EASTMAN & S C H LA FLY La w Of f ic e s FIRST NATIONAL BANK BUILDING -ALTON. ILLINOIS December 4, 1942 Dr. W. J. Siebert Care DePaul Hospital 2145 North Kingshighway St. Louis, Missouri Dear.Dr. Siebert: I have been checking the records in the lead cases which we have tried and also the reports of the courts of last resort throughout the country on lead appeals, and find that the latter, at least, are rather unanimously in support of your view that the best laboratory for lead tests is Kehoe. I have also checked the Compensation Law of this state and find that it fermits the taking of depositions of witnesses outside he state. Under these circinstances I have conferred with Dr. McCuistion with reference to the advisability of making future lead analysis by Kehoe and then taking his deposition in Cincinnati to avoid the expense of bringing the technician to Alton to testify. Dr. McCuistion agrees that in view of K e h o e fs standing and your opinion as to his worth that we would present a strong case if we could secure negative analysis frogi him. Will y o u therefore be good enough, upon receipt of this letter, to communicate with Kehoe and be in position to let me know the following items as soon as possible: ' 1. The fees of Kehoe for making the necessary laboratory examinations in each case (urine, blood, feces); 2. The time probably required for making analysis after receipt of the specimens; and 3. The charge by Kehoe for his laboratory technician, over and above the charge for analysis, for testifying on deposition at Cincinnati as to the results of the analysis. Since seeing you last another lead case has been filed against Western, and if the arrangemaats I suggest X S 00128 Dr. Vv. J. Siebert -2 December 4> 194-2 can be made with Kehoe it is my intention to place both the new lead claimant, and Tayon, the lead claimant upon whom we have not yet made any specific test, in St. J o s e p h 's Hospital at the same time, and have you and Dr. McCuistion get the necessary specimens from both of them and ship them on to Cincinnati. Since we are rather pressed for time in these matters I would greatly appreciate it if you will immed iately write to Kehoe so that we can be in a position to proceed without delay. EB C, cc: Dr. H. P. McCuistion First National Bank Building Alton, Illinois Le 9 00129