xt73bk16mf8w_824 https://exploreuk.uky.edu/dips/xt73bk16mf8w/data/mets.xml https://exploreuk.uky.edu/dips/xt73bk16mf8w/data/51w14.dao.xml unknown 35 Cubic Feet 77 boxes archival material 51w14 English University of Kentucky Copyright has not been assigned to the University of Kentucky.  Contact the Special Collections Research Center for information regarding rights and use of this collection. Louisville and Nashville Railroad Company and Lexington and Eastern Railway Company records Railroads -- Appalachian Region -- History. Railroads -- Kentucky -- History. [677] Laura Whitaker v. L&N, Perry Circuit Court text [677] Laura Whitaker v. L&N, Perry Circuit Court 2016 https://exploreuk.uky.edu/dips/xt73bk16mf8w/data/51w14/Box_70/Folder_7/13264.pdf section false xt73bk16mf8w_824 xt73bk16mf8w \JES‘MORGAN LEWWSAJKUCKOLS
MORGAN5ENUCKOLS 3'“jW~9?
~ " ex
Attururge :11" £21111
HAZARD, KY.
“arch l, 1917.

Judge Samuel M. Uileon,

Lexington, Ky.
Dear sir: Laura Whitaker vs. I a H.

We are in receipt of yours of the 28th enclosing letter of
Mr. Hardesty and section foreman's report of this matter.

Yours very truly,
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February-~27th--l 7
IN YOUR REPLY REFER
TO DATE AND FILE NO‘
2 l 4 5
Mr. Samuel M. Wilson,
Consal,
Lexington, Kentucky.
Dear Sir:—

Your letter of February 9th, suit of L. Whitaker, v.5 this
company, to recover $100.00 alleged value of cow claimed to have
been killed on October 19th, 1916.

I send you report and letter from the Q“took; Claim Agent
who indicates that he tried to make a settlement by offering $50.00
which was the value of the/cow in his opinion., You will note

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Yours truly,
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 JESSE MORGAN LEWISA NUCKOLS /_, .
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\\\4ORGAN & HUCKOLS 714. ,..x z .,
Attnrurgﬁ at 121m
HAZARD, KY. ﬁ
Feb. 10, 1917.

Judge Samuel M. Wilson,

Lexington, Ky.
Dear sir:

Enclosed herewith, we hand you the usual coPies of peti-
tion and docket report in the case of Laura Whitaker vs. L 80 N.

Yours very truly,

JM-L / , '

 ‘3 .
Perry Circuit Court.
Laura Whitaker Plaintiff
vs. / Petition.
Louisville a Nashville R.R. Co. Defendant.
The plaintiff, Laura Whitaker, states that the defend—
ant, Louisville & Nashville Railroad Company, 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
the operation of a railroad through Perry, Breathitt, Letcher and
- other counties in Kentucky and in other states of the United
States, and as such corporation, has the power to contract and to
be contracted with and to sue and be sued in its corporate name.
The plaintiff, Laura Whitaker, for her cause of action
herein against the defendant, Louisville & Nashville Railroad
Company, states that on the 19th day of Oct. 1916 in Perry
County, Kentucky, the defendant run over and killed a cow belong-
. ing to this plaintiff with one of its railroad trains; that the
railroad of the defendant passes through the farm on which this
plaintiff lives and resides and that its right of way is not
fenced, and that the residence in which she lives is on one
side of the defendant's said railroad and her barn on the other
side, and that on said date while her said cow was crossing
said road frOm the house to the barn, the defendant, through the
negligence of its employee and agent ran over her said cow and
knocked her off of its said railroad track, instantly killing '
her. .
She states that by reason of the defendant's negligence
‘ in running over her said cow and so killing her, she has been dam- I
': aged the worth and value of her cow. She states that her said .
i.> cow was five years ohd, weighing about 1000, deep red in color, V

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2
milk
and was a milch cow, giving about two gallons/per day and was
‘ pregnant with calf and would have and was due to deliver a calf
and be fresh with milk in two months after she was killed, and
was reasonably worth the sum of $100.00, and that by reason of
the defendant's aforesaid negligence, in negligently running over
‘ and so killing her said cow she has been damaged in the full and

just sum of $100.00, which amount she ought, as she believes, to
recover of the defendant. She states that the defendant has failed
and refused to pay her for said cow, or for the damage sustained
by her by reason of its having killed her.

warriors, the plaintiff, Laura Whitaker, prays
judgment against the defendant, Louisville & Nashville Railroad
Company for the sum of $100.00 damages and the cost of this
notion did all groper and Cgﬁltﬁﬁlﬁ rrlidf. .rm~

W

The plaintiff and affiant, Laura Whitaker, says that
the statements contained in the above and foregoing pleading,
are true as she believes.

Subscribed and sworn to before me by Laura Whitaker,
this the ____ day of , 1917.