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 JESSE MC.‘SN LEV/ISA NUCKOLS
MORGAN 5c NUCKOLS

Aftnrurga at ”1:21:11

HAZARD. KY.
Sept. 27th, 1917.
Mr. E. L. Wilson,
Lexington, Ky.
Dear Sir:-
D. H. ADAKE VS 1. & H. R. E.
Elease let us have investigation report and statements
in this case so that we may prepare it for trial.
Vew truly.

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 use" MORGAN LEWISA uucKOLs

MORGAN 5c NUCKOLS

Afinrnrge at Emu
HAZARD, KY. >
June 18, 1917.
Samuel M. Wilson, Atty.,
Lexington, Ky.

Dear sir: D.H. Adams vs. L & N.

Replying to yours of the 15th. Not having any report of
this case and being required to 00mplete the pleadings during
the last term of court, we filed a demurrer and upon that being
overruled, filed an answer. A reply has been filed to the answer

, and the issues completed.fl;t is tflirefore too late to make the
motions suggested in Mr.¢iorgah4% _etter to you of the 14th.

As you no doubt know, we have to practice law in a way
somewhat out of the ordinary in this section of the state. We
have always found it advisable to give as little suggestion as
possible to the attorneys for the Opposing party, toward making
up their pleadings and preparing their cases for trial. The
plan we, in most instances, follow here,is to demur to pleadings
hat we do not consider sufficient and let the demurrer be over-
ruled without argument and after the trial of the case, take
advantage 0f the questions in making motions for peremptory
instructions, as suggested in Mr. Warfield's letter. We find
that to follow any other practice which will result in sugges-
tions to the plaintiffsfwherein their pleadings are deficient,
will instruct them in what is necessary to make their case and
when this is done, they are very apt to procure such testimony
as is necessary for that purpose.

We agree with Mr. Warfield's statement that if this peti- ‘
tion sets up any sort of claim at all, it is for injury to the
plaintiff at a place where the company owed a lookout duty and
not because of the fact that he was living in one of the board-
ing cars while working for the company. As we read the petition
it does not even allege that the plaintiff, at the time he was
injured, was engaged in work for the company.

In this view of the case, of course the petition is not
sufficient and we think it very probable if this fact is not
brought to the attention of the attorneys for plaintiff, that
they will completely fall down in their proof in the case.

Yours very truly,
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D H Adams v. L&h R Co. — Perry Circuit Court - 87421
Judge Samuel M. Wilson,
Counsel, Lexington, Ky.
Dear Sir,
I have not seen until today a copy of the petition
V in this case, which accompanied your letter Feb. 19, to
Mr. Donohue. Nevertheless, I hope the suggestions I am
about to make will be in time:

I am firmly of the Opinion that you ought to move to
strike from plaintiff’s petition all that earlier part of
it having reference to the fact that plaintiff was employed
as a section hand in the extra gang and lived in the board—
ing cars — and everything having reference to the boarding
cars. This is upon the view that plaintiff was not injured
at or about the boarding cars, but elsewhere in the yards,
as the petition shows; and, therefore, there is no prox—
imate or any necessary or probable connection between the
fact that he lived in the boarding cars and the fact that
he was injured in another part of the yards. This view is
fortified by the fact that while the petition alleges that
"while this plaintiff was passing through said yards along
said defendant's railroad track on his way to said cars
in which the defendant had furnished him to live," &C., he

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. ' Sth—2
was injured, there is no averment that the way plaintiff took
was the only way plaintiff could have taken, or the best way
he could have taken to reach the boarding cars. In other

7 words, there is no averment showing any necessary connection,

or connection at all, between the fact that plaintiff lived
in the boarding cars and the fact that elsewhere in the
yards he was hurt by the engine. The petition, stripped
of these immaterial and irrelevant averments, would simply
leave a case of a person struck in the yards by the engine,
such person having no right or occasion to be at that point.
We can probably show that even as to outsiders there is not
a sufficient amount of trespassing at that point as to require
a lookout or other precautionary duty (Jillis‘ Ade. v.
L&N R 00., 164 Ky. 124, 152). And even if this duty were
due to other persons, it was not due to plaintiff (L&3 Ry.
Co. v. Smith‘s Admr., 172 Ky. 117, 180).

If your motion to strike should be overruled, I think
you should object and except to all evidence having reference
to the boarding. cars or to the fact that plaintiff lived in
them. And you can probably also take advantage of the same
question in making your motion for peremptory instruction at
clOSe of plaintiff's testimony.

I understand Hr. Landrum will complete his investigation
in this case shortly, and the result will be sent you.

w
Yours very truly},- : . ~#"“}7r‘2r /{
/, e/y \2 rtf-«f fine
Cy flessrs. Horgan a Huckols, ' District Attorney.
Attorneys, Hazard, Ky. ,

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‘ IN YOUR REPLY REFER
M My,” TOVDATE AND FILE NO.
mI’. 11:1 1'... . ?*1 (31.1., .5..-(3058
unlef Law Agent,
Lauifivillc, Ly.
Dear Sirc~
Refer to Judge ilson's letter of February lgth to the
. * ‘_ ,. .,. _ ... H' M _ ._ LL .- .. n
ASSledfli alsbrlct AbuOPan, salt of 4. u. naams to recover .l0,000.00
for injuries Claimed to hahe bee: suabaian at hazard on
day of Jocenber, 1916.
1 Rang you ncrswitk my file 1-6058 ThiCh chews an injury
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 \JESSE MORGAN LEWISA NUCKOLS
”7 r H. . .
[flORGANakNUCKOLs 7£“m’;~f}
Aitnrurga’ 21f Emu
HAZARD , KY.
Feb. 16, 1917.
Judge Samuel M. Wilson,
Lexington, Ky. .
Dear sir:
Enclosed herewith, we hand you copies of petition and
docket report case of D.H. Adams vs. L & N.
Yours very truly,
I? , . ‘ 7 . ‘ i)
’ , /‘,. _ ’7’ I 7: ,r ‘.’I." ]
JDAI‘L K {I (//! 'L //i L); I»I/I: "‘I’/Ii“, 7‘ /v. .»‘L/‘l‘l‘

 ‘ I
PERRY CIRCUI’L1 COURT.
D.H. ADAMS PLAINTIFF
VS. PETITION.
L. 8c N. RAILROAD CO. DEFENDMJT.
The plaintiff, D.H. Adams, states that the defendant,
Louisville & Nashville Railroad is a corporation created,
organized and existing under and by virtue of the laws of the
state of Kentucky, for the purpose of, and is engaged in con-

' struoting and maintaining and operating a railroad line through
Perry and various other counties in Kentucky and in its corpo-
rate name has power to contract and be contracted with, sue
and be sued.

The plaintiff, D.H. Adams, for his cause of action
herein against the defendant, Louisville & Nashville Railroad
Company, states that on the _____ day of November, 1916 he was
in the employment of defendant doing work for it, on its rail-
road line through Perry County and as such employe was stationed
on cars furnished by the defendant for said employees, in which
cars the plaintiff and other employees working with this plain-
tiff, lived, eat and slept and that on said date said cars were
placed and mains ined by the defendant in the railroad yards
at Hazard, Kentucky; that the crew of employees of defendant

’ with whom he worked was called "A extra gang", and as aforesaid,
’ lived, eat and slept in said cars furnished by the defendant for
said extra gang, of which this plaintiff at the time was a meme

bar and which cars were moved about and stationed at different

_ places on defendants raierad line where defendant would have

 work for said crew to do on its railroad track and when wuch
work was completed at one point the defendant would move said
cars and said crew to another point and so on for the purpose of
the crew doing such work as was intended by the defendant it
should do and that on the said date of the day of Decem-
ber 1916, the defendant had moved and stationed said cars tOgether
with said crew in its said railroad uards at Hazard, Kentucky; 1
that said railroad yards at hazard, Kentucky cover about twelve
acres of land and is already closely overlaid with switches,
railroad
sidings and parallel/tracks on which numerous railroad engines
and loaded and empty cars are placed and kept and removed
therefrom as the defendant sees fit so to do and in which yards
the defendant maintains one or more yard crews and one or more
yard engines, the business of which crews are to do the switch-
ing in said yards and making up so loaded and unloaded trains and
that on said date, while this plaintiff was passing through said
yards along said defendants railroad track on his was to said
cars in which the defendant had furnished him to live, the de-
fendant through carelessness and gross negligence ran one of its
. yard engines, which was in the hands of one of its yard crews,
against this plaintiff, thereby injuring him in his back and
both sides and hips and legs and injuring him internally, ren-
dering him unable to do or to perform manual labor and from the
nature of said injuries it is reasonably certain that he is
permanently injured and is thereby rendered permanently unable
' to do or perform manual labor, thus, by defendants carelessness
and gross negligence destroying plaintiffs ability to work and
earn money permanently and through which carelessness and gross
negligence on the part of the defendant resulting in the afore-
. said injuries to this plaintiff he has sustained damages in the
2

 x

‘ sum of $10,000.00 which he ought as he believes to recover of

this defendant. .
Plaintiff says that by reason of the foregoing careless-
‘ ness and gross negligence of the defendant which resulted in his

aforesaid injuries he was compelled to employ and retain a phy- ’
sician to treat him, which he did and which plysieian has treated
him for said injuries during all time since he sustained said
injuries and for which treatment he has paid to the defendant ‘
the sum of $280 and for which this plaintiff is entitled to be
reimbursed by the defendant and as he believes he ought to re-
cover from the defendant the said sum of d280.

Plaintiff says that said accident happened in the rail-
road yards at Hazard, Kentucky in Perry County and that 12 months
has not elapsed since the accident resulting in plaintiffs injury
happened.

Wherefore the plaintiff prays judgment against the
defendant Louisville and Nashville Railroad Company for the sum
of $10,000.00 damages for cost herein eXpended and all preper
and equitable relief. I”

'7 , ‘ . {J #- 4”th $_ ‘32, “(i/:’Lr’
W
V The plaintiff, D.H. Adams, says that the statements
contained in the foregoing petition are true as he verily ve-
lieves.
_____________________________
Subscrioed and sworn to before me this the 8th day
i of January, 1917.
________________________________