Louis Brandeis, St. Louis Company v. United States…
“ Any claim based on a lack of authority in the Director General is clearly unfounded.There is in the brief a suggestion that the lower court erred in giving effect to section 3 because 'the contract was set out as an exhibit to the petition not as a part thereof, but merely for the purpose of showing to the court that the cause of action set out in the petition * * * [was] entirely independent of and arose outside of the contract itself.' The suggestion is unsubstantial. Ordinarily, the defense of release or accord and satisfaction must be pleaded in bar. ”
