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A 1} L>l-' ''\AA . E TH Y L G ASO LINE CORPORATION V Si B r o a d w a y N k \V Y O R K . March 5, 1950. .f- Dr. H. A. Kehoe, College of Medicine, Eden & Bethesda Aves., Cincinnati, Ohio. Dear Dr. Kehoe: Enclosed is copy of letter from Mr. Stryker to Mr. Johnson of the 1st which was sent to us by the latter with the request that we ascertain your views concerning the question of Mr. Stryker. Will you kindly let us have this information at your earliest opportunity. A:H copy LIXMBUEY, UEFUS & FAULKS Prudential Building 763 Broad Street, IJeviard, If. J. ST^U)ABB OIL 00. March 1, 1930 3dv.ard F, Johnson, Esq. Standard Cil Company 26 Broadway Jew York, H. X. Bear Mr. Johnson: I have your letter of the 7th uit., enclosing copy of letter from T>r. Xehoe. ____ As I understand Br. Kehoe's letter, It is Based apcn condition in 1926, v;hich he says was a year after the alleged exposure. Suit in. this case was commenced on October 15, 19L9, and, in ray judgment, any claim for exposure prior to 1926, which resulted in an illness in 1926 -would .be barred by the Statute of Limitations. Evans will undoubtedly claim, however, that he was exposed to tetraethyl lead within a period of two years prior to the commencement of the action and it may be that he will also claim that the later exposure was more harmful to him because of his previous exposure than it otherwise would have been. I would like to have Dr. Sehoe* s vie as to whether any such claim could be sustained if made. While, of coarse, I shall reserve decision as to the defenses which should be interposed to the suit until after the Bill of Particulars has been received, it Is my present view that we should pleadeall of the defenses pleaded to the other suits and that it is quite possible that the Statute of Limitations may play a very important part in the litigation. I do not know why the Bill of Particulars has been so long delayed unless, perhaps, Mr. Gordon is having some difficulty in stating his case so as to avoid the defense of the Statute of Limitations. \rery truly yours, JS'iEAS (Signed) Josiah Stryker Mr. b. .7 Met)o, "thyI Gasoline Corp, 25 Broad-say,, Hew York City. Gear Mr. Mebb; In my conversation with Lir. Johnson of the standard Oil department last Tuesday I outlined brief ly v/hat appeared to me to be the important facts in this and in similar cases, attempting to make clear from the point of view of mdical expert what it would be necessary to demonstrate in order to bring such a ease to a satisfactory conclusion. Mr. Johnson asked me to expand' the subject somewhat in a letter to you, rhieh might he transmitted to him at your pleasure. I have followed Hr. Johnsons request and am enclosing herewith what seems to me to be a fair anal ysis of this ease on a medical point of view. There may be certain facts and details involved on v/hieh there is not absolute unanimity of medical opinion. In general, however, the outline of the subject is accur ate and all of the factual details are tenable. at least it represents the sort of evidence that I would consider it necessary to present in a case of this sort. I am enclosing a copy for Mr. Johnson if you wish to place it in his hands. I ara certainly grateful for .your telegram of last Friday informing me that it was unnecessary for me to go to Boston. I am sorry indeed if I gave you the impression that I was not entirely willing to go do Boston if necessary, for I should not wish you to feel that you need hesitate in asking my services in such a matter. However, I was very happy that it . was not necessary for me to go at that time, for you can probably understand fcht there are many things here that need looking after. It was a great pleasure to see you in Hew York and to have an opportunity of talking over some what fully a number of important ibatters. Kindest re gard s . . Sincerely yours, 0017453