Document v6QjzM9QZBave9Yxnxybj3Z39

FDrRo.mRthOeBdEesRkTofA. KEHOE > L ^ W, ^ y^* 4 -4^> jt sHv ^ A V**$i^r */jv x &> KF" 0011953 fe - w ffoaasr ss- 'i t k a k f . m . h= H07 BULL STREET s a v a k k a h , g a ., July 1st, 1937. Dr, Robert m. Kehoe, College of Medicine, Cincinnati, Ohio. .. Dear Doctor Dehoe: I an returning today holders containing specimens of blood and arine of Mr. af? rsr cur 2!.g cent correspondence. Thanlcin : you ver;/ inuch for the interest you nave tnhen in tins case, X am, b( 0011954 mm. iM bgK W U '- 'hF. -J.,i E.,. Stth m ~ ii8 p TOMES M o 1107 BULL STREET 1237. Dr. Hobert- Ai^e-hoe, University of/Cincinnati, laboratory of Applied Physiology, Cincinnati, Ohio. ' My dear Or. lielioe: - Your very kind letter of June 12th was read with a great deal of''interest, and I Must say rather coincided with ray train of thought, as it was almost inpossible for no to con ceive of lead poisoning under circumstances as told by the patient, but 1 have only seen the nan on one occasion and then not for anamination, cut just for a conversation. I feel that it has beer, so long ohat the urine and blood vould show nothing at this tine, but the m u is so anuious to feel that something is being done for him that 1 believe at least the psychological effect would be good. 1 would, there fore, be very grateful if you would send me proper containers in which I will get the blood end urine and m i l them out to you immediately. I i DR. vJ. C. M E T T S SAVANNAH, GA. September 21, 1938 Dr. Robert A. Kehoe University of Cincinnati College of Medicine Cincinnati, Ohio ' Dear Dr. Kehoe; . Thank you very much for your kind letter this morning. As . a matter of fact, I had only this morning called the attorney who is representing the Oil Company to know when this case would come up. As soon as he notifies me, I will get in touch with you. 1 am very much afraid that it will be necessary to trouble you to come down inasmuch as weshave no one with any particular knowledge of the subject available near here. I m i l write you more in detail later. With kindest regards and best wishes, I am Yery sincerely, K f 0011956 September 19# 1938 Dr. J* C. Mefcts Savannah, Georgia Dear Doctor Mefcts In reply to your letter of June l6th, I think I should let you know that I have returned to ray work and will be available in connection with the case of alleged lead poisoning which you brought fco my attention some months ago#' If there are any further developments in this case, I should appreciate knowing about them, and if ay services are required I should appreciate your, letting me know as far in advance as possible. Very truly yours, RAKsls Robert A.' K.ehoo," li.D. He 0011357 w. '-T- ~ DR. J . Si METTS SAyANNAH.GA. June 16, 1938 Dr. Robert A. Kehoe University of Cincinnati Cincinnati, Ohio Re: Lead poisoning Dear Dr. Kehoe: Thank.you very much for your kind letter of June 10th. I immediately got in touch with the attorneys who are defend ing this suit. Inasmuch as you are going abroad on June 22d, we felt that it would hardly be worth your time to com down as the plaintiff's attorney stated that this man was in the country and could not be brought in until next week. Mr. Atkinson, who is defending the oase, suggested that the case might be postponed until your return if you could give me an idea of approximately when you will return it would help to decide this. I wish to thank you for the reprints. Am planning to examine this man in consultation with several other physicians and will send you a copy of our findings. We will, of course, be very glad for you to examine him also and will be grateful for any assistance or suggestions which you may see fit to give. With kindest regards and best wishes, I am Very sincerely, . K 0011958 ua 10* 19 5 8 Up * J* A. Cos tall MShyl Gasoline Corporati a Khodea**Baverty Building Atlanfeai Georgia.- . Dear Mr#Costellos- Thank3 for your letter of Tune?* and Its enclosures concerning the case of alleged lead poisoning in Savannah* `This ease has all the earmarks of a rather serious on in that the type of injury complained of resembles lstd poisoning in some respects and it siill be necessary to Investigate it as thoroughly as possible. I have therefore written to Dr# Metfes at some length after receiving: letter from him about the ease# I should appreciate- it if you uould pass on to us.as promptly ae possible any further information which you may receive* loreovef whatever assistance you can give in' collecting information without involving the Ethyl ~ Gasoline Corporation in any nay should he given toward clarifying this case# Cordially yours RAK$ltft ecilir*-' t o is HSEertT \(g 001ir?5y ISP ! c INTER-OPFtCE o r r e s po n de n c e ; Et hyl Gasol ine Corporat ion - At l a nt a .Of f ic e R h o d e s -Ha v e r t y B u i l d i n g A t l a n t a , G e o r g i a J une 7, 19 3 s , 'Dr* Robt. A. Kehoe, Cincinnati, Ohio. `. Dear Dr. Kehoe, I am attaching a letter from our Georgia representative which contains information about an investigation he made of an alleged lead poisoning case in savannah, Georgia. As is indicated by his letter, we were advised of this by the marketing company supplying the gasoline, and have taken no part in it other than to get whatever pertinent information we could. There is also attached a copy of the Plaintiffs Petition which was filed in the City-Court of Savannah and upon which the suit will be based. Ae are passing this along for your information for any disposition which you wish to make of it. Very truly yours, j a c /f .l enclosure 'S'-'."-."--v f . CC-Mr*Lewis -- m i,- y KE 0C.1DO y it . = . f y j gTl-.' A THE CXTX CO-J 1 l,rrr.. An Chatham c o ht , geosjia _ TO Tiil-: OiOIiAUdi Tilii CITY COURT OF SAVANNAH! The petition of respectfully shows the following faots I The defendants in this cause are U CLARK ABBOTT and 3. KERHELLE MOCKand A. &M. .BRECJ53BOAMD PARTS COKPAKXj . .II ' ' ' 13. CLARK ABBOTT and J. MKRRELLE MOCK are residents of Chatham County, Georgia/ at all times mentioned in this petition; said Abbott and Hoek were engaged together as co-partners in business under the name and style of A. and M. MH4CJ2H3 _AHD PARTS COMPANY which business was located in said County on, the Coastal Highway about one mile north of Savannah; f III The-business in which the defendants were engaged at said location was, among others, the seeking and salvaging, purchase and sale of motor vehicles and parts thereof; the disassembling, repairing and sale of motor vehicles and parts thereof; IV On May 0, 1936, plaintiff was in the employ of defendant; at their said place of business as an automobile mechanic, having- been so employed by them for about a year prior to said date; V Plaintiff's duties as such employee of defendants were, among other things, to disassemble motor vehicles and to clean / and repair octoh parts of seld vahiolaa as sore suitable 'or acle or further use; . VI Many of the parts so taken by plaintiff from such motor vehicles, and parts which it was plaintiff's duty to clean and repair, were so covered with grease and dirt that it was necessary and was part of plaintiff's duty, to wash them in a liquid or solvent that would soften and remove such grease and dirt; KE" 00.11961 ' ' STtfsira w w - i * (S'r.wv: ;ca at?" c r a x ofTKK oi g?&Kgrg :..li,..;..,^,,,^,,^^.^--^^ VII In washing end cleaning such parts*which was a part of plaintiff's duty as employee of the defendants, and under the instructions and authority of defendants, Abbott and Kook, plaintiff used the materials and equipment furnished him for tills purpose by the defendants; VIII For washing and cleaning such parts, the liquid or solvent so furnished plaintiff by defendants was gasoline containing lead; IX . Obedient to the authority and Instructions of defendants, in washing and cleaning such parts* plaintiff used the gasoline so furnished him b y the defendants! X. In washing and cleaning said parts of motor vehicles as aforesaid, it was necessary that plaintiff!s hands and other parts of his body should be frequently exposed to and wet by the gasoline which was furnished to liia by defendants and which he used for this purpose; XI On Hay 20, 1936, plaintiff suffered lead poisoning, which was caused b y absorption into plaintiff's system of lead from the gasoline containing lead which was furnished to him by defendants and which, as aforesaid, he used under defendants' instructions to him as their employee; XII She absorption of lead into plaintiff's system from said gasoline containing load was caused b y plaintiff*s use of said gasoline in performing the work for which he was employed by the defendants, using the gasoline furnished by the defendants in obedience to defendants' instructions; XIII She results of said lead poisoning to plaintiff have been, since May 20, 1936, the followings KB 001196 2 .. - ^"i :g-.5?: '. ' ''. ", -'- ' iio stiffera paralysis of the wrists which is know as ''wrist drop" and paralysis of the ankles which is known as "ankle drop"; the muscles of plaintiff's legs ankles and feet 'nave wasted and become flaoid and weak; he has lost# almost totally, the use and control of .his ankles and feet 5 he can walk only haltingly and with greet difficulty; the muscles of ' plaintiff's arms, wrists and hands have wasted end become flacid and weak; he hhs lost, almost 4otaily* i^i ws of his wrists and hands; the muscles of his hands and fingers, on the under side or palm side of his hands and fingers, are drawn so that his fingers are held in a claw-like half-closed position; and from said lead poisoning, plaintiff suffers disturbances of his nervous system, impaired digestion, poor nutrition, anaemia and weakness. Said impairments of plaintiff's body and health are incurable and permanent; by them he is totally disabled to engage in any gainful occupation sad will remain so disabled the remainder of his life, XXV fhe disabilities, impairments and injuries set forth in the next proceeding paragraph of this petition were caused to plaintiff by lead poisoning contracted by the use by plaintiff of gasoline containing lead, which was furnished to plaintiff by the defendants imd was used by plaintiff in obedience to the defendants' instructions, as is set forth by this petition; . XV Neither of the defendants warned plaintiff that there was lead in the gasoline which they furnished him to us in his said work in their employ, or that such use of such gaeoline was accompanied with any danger to plaintiff's health a- person* XVI Defendants furnished plaintiff no safeguard or protection against the absorption of lead into M s system from the use of gasoline containing lead, as aforesaid; nor advised him of the need or wisdom of such safeguard or protection* 0011363 XVIII When the defendants furnished said gasoline to plaintiff for use by U * , aforesaid, the defendants, end esCll of tbw,- knew or should have known, and b y the exercise of ordinary care wouldjheve known that such gasoline contained lead; ',, 0011964 **326x4*13~-\fi'Vnjcyca*~T?r7s!i0*0**563 &u*j enixenw 6B*x4ys- on ispo Krai npyc-P re jcscjs? XVII then plaintiff used sale gasoline as aforesaid, He did not know said gasoline contained lead and did not know that the use of gasoline containing lead was dangerous to the health oi* body or members of the person so using it. He relied upon the discretion and care of the defendants to furnish M e only such materials for use in doing the work assigned to him b y them, as could be used with safety* By the exercise of ordinary care, ha could not know that the use of the gasoline furnished him by defendants, as aforesaid, was accompanied by the danger of lead poisoning* XIX . Shan the defendants furnished said gasoline to plaintiff for use by Him, as aforesaid, the defendants end each of them knew, or should have known, and b y the exercise of ordinary care would have known, that such use of said gasoline was accompanied by the danger of lead poisoning to the person so using it; XX i'he lead poisoning suffered by plaintiff and the injuries to plaintiffs person end health, hereinabove set forth by this petition, and the resulting loss and damage suffered by plaintiff, as ore by this petition hereinafter set forth, were caused by the negligence and lack of care of the defendants and each of them, as follows: (a) In furnishing to plaintiff, as aforesaid, gasoline containing lead with which to clean automobile parts; (b) In requiring plaintiff, as aforesaid, to use gasoline containing lead with which to wash automobile parts; (c) In failing to inform plaintiff that the gasoline furnished to him for washing automobile parts was gasoline' containing lead; id) In failing to inform plaintiff, or warn him, that the use of gasoline containing lead, for washing automobile parts, was accompanied by danger of lead poisoning; KX 0011365 ----- ------------- -- :--- '---- -- -.. .. ;.;' F vr (e) In failing to inform plaintiff, or warn him, that the use of the gasoline furnished plaintiff, by defendants, for sashing automobile parts was accompanied b y danger of lead poisoning; ... .- (f ) In failing to provide plaintiff with any safe guard or protection against the absorption into his system of lead from the said gasoline containing lead; (g) In falling to advise plaintiff of ,the used or wisdom of using some safeguard or protection against the absorption into his system of lead fresa said gasoline containing lead. XXI At the time plaintiff became disabled b y lead poisoning, as aforesaid, he was a mechanic and was earning Eighteen Dollars ($18.00) per week; XXII At the time plaintiff became disabled, as aforesaid, he was twenty-nine (29) years old and had a life expectancy of thirty-five (35) years; XXIII Plaintiff's ability to work and earn money lias been, b y said lead poisoning, totally destroyed from May 20, 1936, for the remainder of plaintiff*s life; by the said loss of his ability to work and earn money he has been injured end damaged in the sum of fen thousand Kino Hundred Forty-four Dollars ($10,944.00); XXIV Because of said lead poisoning, plaintiff has incurred end suffered the lose of the following expenses which were necessary in the treatment of his said malady* For services or physicians For services of trained nurses For male attendant For hospital feArvice f or board of trained nurses For drugs and medical supplies For treatment and expenses at Hot Springs, Ark, For Electric vibrator For extra domestic servant 284.00 227.60 55*00 "38'.00 43.51 135.11 10.00 35.00 807.62 For the i'ects Bet forth by this petition plaintiff shows that defendants have damaged him is the sum of Sieves Thousand Three Hundred and Six & 62/100 Dollars (iHS06*62)| ttHEREPOns plaintiff prays that he have judgment against defendants D, Clark Abbott and J. Merrelle Hook end A* and U, '.'.recking and Parts Company and. each of them for the damages by this petition set forth in tins sum of Eleven Thousand Three Hundred and Six k 62/3.00 Dollars ($3.1,506*62}* AKD that process issue requiring the defendants t B* Clark Abbott, J, Merrelle Mock and A* and H. Wrecking and Parts Company, and each of them, to be and appear at the next tern of this Honorable Court to answer plaintiff's petition* Plaintiff's Attorney at Law KB 0011987 StatCeooufn(tG(yTeioot?frgCoiaffySatafvyaamnna!) TOTHE SHERIFF OF THE CITY COURT OF SAVANNAH, GREETING: T.'= ' D. CHARS ABBOTT AMP J , HERRIEEE KOOK, and A. & U. v/KECKHG AND PARTS' COEFAIIY, The defendant..?.__J?.s....QHARS_.ABBOTT..AND..J.....M^KRIJi0i..jS.OOjS...-8'Ildi..A..j&..K.................. V.KECKIRG AHD PARTS COMPANY........................................................................................................ .........hereby required, personally or by.-- A.?....Attorney, to be andappear at the next CityCourt of Savannah, onthefirst Monday, being the............................................................................ day of............."i?'.?.!..............................................next, then and there to answer the Plaintiff on the merits of the foregoing petition; as in default of such appearance the said Court will proceed as to justice will appertain. AlexanderR. MacDonell, WITNESS, the HonorableIWWIIlifflPWWFIfJJudgeofsaidCityCourt, this........18th.......dayof Bey\ of our Lord, OneThousandNineHundredand--.i^^i?"AS.^.. Dept' - ClerkCityCourt of Plaintiff's Attorney. ....................................................................Plaintiff, vs.....................................................................Defendant Therebeingnoissuabledefensefiledonoath inthis case, judgment is renderedbythe Court for the Plaintiff against Defendant for.....................................................................................Dollars and .............................................................Cents, principal.................................................................Dollars and ...................................,......................Cents, as interest, and......................................................Dollars and .............................................................Cents for cost of suit. In Open Court, this..'.......................day of.....................................................19,........,. Judge City Court of Savannah. -* Personalserviceofthepetitionandprocesshaving been made upon Defendant and there being no denial of any of the material allegations of the petition, and a default having beenentered in said case, upon proof submitted judgment is rendered by the Court for the Plaintiff against the Defendant for....................,................................Dollars and..................................................-Cents, principal ....................... --v-...........-..................-...........Dollars and....................................................Cents, interest and ....................................................................Dollars and....................................................,.........Cents for cost of suit, and all future interest and cost. In OpenCourt, this..........................day of.....................................................19______ Judge City Court of Savannah. 3 .Plaintiff, vs. Defendant Thejury empanelledtotry said casehaving on the...............................................................,,.day of....................................................................., 19...........returned a verdict for Plaintiff for the sum of ......................................................................Dollars and...........................................................Cents,-principal and .................................................................Dollars and.....................................................Cents, interest Judgment is rendered for the Plaintiff against the Defendant forthe sumof........................................ ..............................................................1____,,.... Dollars and_______;.__________________Cents, principal and --.................................................................Dollars and......................................................Cents, interest and .....................................................................Dollars and........................................................Cents for cost of suit, and all future interest and costs. . , This....................................day of...................................................19........... Judgment, Signed and Filed this. ...day of.:. Plaintiff's Attorney. ..................19._____ Clerk, City Court of Savannah. Jf i j j | | 001 1363 r* c- '/ J \ EDMUND H.ABRAHAMS JOHN U. BOUHAN DAVID S. ATKINSON ALEXANDER A.LAWRENCE CABLE ADDRESS ABALAW Ab r a h a ms , Bo u h a n , At k in s o n Sc La w r e n c e ATTORNEYS AND COUNSELORS AT LAW FOURTH FLOOR COMMERCIAL BUILDING SAVAN NAH, GEORGIA - April 6th, 1939 o*3**L. f VUWx-u 1,f` i VU-^ H Dr. Robt. A. Kehoe, University of Cincinnati, College of Medicine, Cincinnati, Ohio. - -, - , ?.. Dear Doctor; -: . RE: v. A. & M. City Court of Savannah- Suit for damages We. w i s h to a c k n o w l e d g e r e c e i p t of your letter of April 3rd. ; A p r i l 10t h Is so close upon us that it w i l l not be possible to arrange an assignment on that date. Since your engagements preclude your presence here du r i n g the r e m a i n d e r of April, we w i l l endeavor to get the case set for sometime In May, or the first part of June. If you will let us know when you will be avail able, in May and June, we will try to arrange a date that will be co nve n i e n t to you. Will you, therefore, please advise us at what time during May or June you will be available. Give us as many dates as you can because we have to fix a date that w i l l be agreeable to the Court, to counsel, and to some of the other interested parties In your letter of June 10th, 1938, to Dr. Metts, you state that HInvestlgations of this laboratory, of the U n i t e d States Public H e a l t h Service, and of the B r i t i s h M i n i s t r y of Health failed completely to show any evidence of danger f r o m lead absorption as the result of contact with gasoline containing the commercial quantities of tetraethyl lead." We think it would be h e l p f u l to the case if we could get a copy of a ny reports of the U n ited States Public H e a l t h Service or the B r i t i s h M i n i s t r y of H e a l t h to this effect, or if we could take the t e s t i m o n y of someone in either of these D e p a r t m e n t s , .. showing this o b s e r v a t i o n to be the re s u l t of e x p e r i m e n t s and information received by the departments. Kg' 0011370 Dr. Robt. A. Kehoe 4/6/39 Can you suggest some way that we may get this evidence, either by depositions or interrogatories, or in the f o r m of o f f i c i a l reports so As to h a v e it b e f o r e the Court when the case comes on for trial* Thanking you for your kind consideration, we are DSA:epc Yours very truly, A B R A H A M S ,B O U H A N ,A T K I N S O N & LAWRENC1 /' /\ jXjf y / S. A T K I N S O N V He 0011971 Ms*.David 3. 'Atkinson : Abrahams* Bouhan* Atkinson #n&..L&tfren00 Fourth Floor Caare relaX Building Savannah* Georgia , . ; . , . Dear Mr. Atkinsonj . . - . ' Xn reply to your letter of April 6th* X-dm-giving-you herewith l l s i ^ ^ ^ e n . ates for four convenience la setting the case. X find. I have no fixed appointments for the week begin ning .Sunday* May 21st and. for., tbs following week May 28th. I shall be involved in several engagements during the first week in dune* but- for the week of dun llth and for the week immediately following that* X have no fixed appointments at this time, '... . X hop'yon.will fee able to set the case during on of the times X have indicated, and X would appreciate it very such if you would com municate the- -final date to me. prosily;- since it will be- difficult''for me to keep all of these week# free of engagements* , :* During the .past, two weeks X have been going over some records which have aceumu- >.,vc? .=- ,--j7.v'V lated over a period of months, To my surprise I found that Dr. dohn K. Train of Savannah wrote to on of my associates on June 6* 1937 reporting In some-detail the 'fCt illne# and the occupational history of one Lonnie 0, Mrton,and suggesting that we might b e .interested in locking into thi# case in as much a# a .number of physicians , had made a diagnosis of lead poisoning* My associate. Dr. Kitsrailler# brought the matter to my attention after having written to Dr, Train and after having expressed the opinioull: that the patient was probably suffering from a severe virus infection of the central nervous system, which had produced?-v-' an acute pollomyelencephalitIs, X wrote to Dr* Train, ; expressing ay essential agreement with Dr, Kitrmiller*# opinion but offering to meke some analyses on the urine and blood of the patient. Samples were received on July .-'r, 6th, 1937 aad were analysed and reported to Dr* Train o a :i4i':- i July 9th, 1937* fh results were well within the range c - of normal values and were* in fact* lower than those usually seen in normal persons; This infom a t ion, I believe* will, be quit useful 'to you and 2 shall bring the entire file of correspondence with me when 1 some* . With respect to the reports of the United States Public Health Service and of the British Ministry of Health, I am sending to you under separate cover one copy each of these bulletins* Both of these are from my own collection of material and although 2 realize their importance to you, 2 should be loathe to lose them by having them presented as exhibits In this case, Obviously if it Is necessary to put them into the record* you will have to do so* but I trust that this will not be necessary and I shall be glad to get these bulletins bach again, ` : . .. . ' fery truly yours* : RAKj8 SSSSifX"TShoS71!^7 V " C ' .S'? Tele gram Relet April 3rd CANNOT SET CASE APRIL 10th LETTER FOLLOWS. '- D a v i d S. A t h i n s o n K'r 0 0 1 1 . 3 ? 4 chiusi EDMUND H.ABRAHAMS JOHN J. BOUHAN> ; DAVID S. ATKINSON ALEXANOER A.LAWRENCE CABLE ADDRESS ABALAW Ab r a h a ms , Bo u h a n , At k i n s o n & La w r e n c e ` r- ATTORNEYS AND COUNSELORS AT LAW ' FOURTH FLpOR COMMERCIAL BUILDING 5AVAN NAK,G ERGIA April 1st, 1939 Dr. Robert A. Kehoe, Associate Professor Physiology, University, of Cincinnati, Cincinnati, Ohio. Dear Doctor R E VS. ABBOTT & MOCK, ges- City Court of Savannah for alleged lead poisoning from use of Ethyl gasoline Dr. Metts of this city advises us that he has b e e n in co r r e s p o n d e n c e w i t h you in ref e r e n c e to the above ca s e t This case will come on for trial at the present term of Court, sometime during this month, and at the suggestion of Dr. Metts we are w r i t i n g yo u to ask if you can give u s . s o m e late information upon the subject of lead poisoning from the use cf ordinary motor vehicle gasoline which has been treated with tetraethyl and contains lead in quantit*T varying from a p p r o x i m a t e l y .7 cubic c e n t i m e t e r per g a l l o n to a p p r o x i m a t e l y 1.3 cubic centimeter per gallon. - Dr>.;Metts has also s u g gested that you m a y be w i l l i n g to come to S a v a n n a h and advise w i t h us in the p r e p a r a t i o n of the trial of the case. We can have the case set for trial on almost any day inf April, except Friday, Saturday, or Sunday, and if you can h e l p us in the case, we w o u l d like for you to advise what d a y w o u l d b e suitable to you. . ' Thanking you for your cooperation, and with assurances of our high regards, we are DSA:epc 0011375 April 3*1939 i-'. Barrici 3. Atkinson ` Abrahams, 3ouhan* Atkinson and Lawrence Fourth Floor Coirnerelai. Buildlag Savannah* Georgia Boar Stri- I have your letter of April 1stconcerni ng the Impending trial of the .'case of versus Abbott and Hooh. . . Sosa time ago I had some borrespon&ence with Dr* Mats of your eity and 1 sent him a number of articles which gave the essen tial information and the investigation of the potential hazards associated with the handling of gasoline con taining tetraethyl lead, There is little or .-nothing which can he added to the information X gave Dr. Metz except to say that no tiling has occurred since my correspondence with'him' to alter the facts in -any way. do far" as my mow!edge goes* there has hover been a case of lead poisoning from the handling, of gasoline containing tetraethyl lead#, eves in the maximal con centrations which are permitted commercially. She accumulated evidence of the years would tend to demonstrate that no such cases of poisoning are likely ever to occur* There is* in fact* no evidence whatever that there is any likelihood of lead absorption among persons who handle such gaspline* ~ X feel that under the circumstances if would be advisable for me to give my assistance in your preparation for this case* and X shall try to make sueh arrangeaents as will permit jae to do so* Bufortunately^ h o o v e r * April Is a rather busy month and I have a number of engagements which make it difficult for me'to be away from home for longer than a few days at a time. In fact* the only free date which 1 can see a s a logical one is on Monday * April 10th. Xt will be absolutely necessary for-me to- be -fn-Oinoinratl on Thursday the Ipth. Therefore* if X am to be of much assistance to you* X think It might be well if you were to arrange the date for the beginning of the case for Monday the 10th.# in the hope that it could be completed some time on Wednesday* the 12th. X realize that"in making this suggestion* X am anticipating that it will take several days to cover this case* X may be wrong but my previous experience with cases of thlc type indicates that a con- - y . *' . . ' 4M ^ **? siderabl amount of time is required in the presentation of the facts* especially if the case has been well prepared . by both sides. In this latter connection* it might be well . : if I let you know that I had been consulted indirectly by opposing: attorneys in this case to i*hom I gave the same hind of general information that I gave to Dr. Metz* although not to quite the same extent. I merely make mention of this la order to indicate that opposed council has apparently made rather extensive attempts to obtain information, By reason of the fact that X have no engagements after the middle of this week* X could be with you on, Saturday* April Sth in order to go over the various aspects of the case* if you consider It advisable. . ' Pleas let m know promptly what you will wish me to do since X. am Moving some difficulty `T :;- . In arranging my. engagements through the`month of April, r .. : Very truly yours* . R&Ksis Robert A. Kehoe* K.D. `ooi j3y