No. 1217
A. Wilson
vs.
Pullman Palace
Car. Co.12
Interrogatories to
be propounded to
Mr. and Mrs. J. B. Seghers of Cook County Ills.
_____________
Filed February
12, 1889.
A. J. Houston
Clerk
By W. __ McDonald
Deputy.
Annie
Wilson
vs.
The Pullman Palace Car Co. |
|
In
the Circuit Court of the
United States, for the Northern
District of Texas, at Dallas. |
...
[Interrogatory]
To said Plff. Annie Wilson or her
Attorneys of record,
Messers Ball, Wynne and McCart. |
|
Interrogatories
to be propounded to J. B. Seghers
and Mrs. J. B. Seghers, who reside in Cook County, Illinois. |
Int. 1st. State your name,
age, and place of residence and occupation?
Int. 2nd. This is a suit
brought by Mrs. Annis (sic) Wilson to recover damages for an
injury she alleges she sustained by falling from a ladder, while
she was endeavering (sic) to climb into an upper birth (sic)
on one of the cars of the defendant, the Pullmans Palace Car
Co. on or about the 21st day of February 1888, between Colton
and San Diego. She alleges in her petition tha[t] by reason of
the breaking of the step ladder and her fall therefrom, she received
injuries which caused her great and excruciating pain and suffering
of body and mind, and does and will continue to do so as long
as she lives. Do you know the plaintiff Annie Wilson? When,
where and under what circumstances did you know her?
Int. 3rd. If in answer
to the preceding interrogatory you say she came as a guest to
the Hotel Coronado, in San Diego. Then state when she came
there how long she remained, and when and under what circumstances
she left? State how and why you know this?
Int. 4th. Who was keeping
this hotel at this time? If you say you were, and that
Mrs. Annie Wilson, the plaintiff, was a guest in said hotel in
the latter part of February 1888. then state fully what complaints,
if any, were made by the said Mrs. Annie Wilson, during her stay
there, as to any bodily injury, or as to any suffering either
physical or mental, arising from any bodily injury, or signs
thereof you observed her to have, and state your opportunities
for observation?
Int. 5th. State, if you
know what parties, places of amusement or public gatherings,
if any Mrs. Annie Wilson attended during her stay at your hotel?
State, what part if any, the said Mrs. Wilson took in these festivities,
if any such there were. What was her condition, as far
as you could observe, as to suffering either physical pain, or
mental anguish on account of any bodily injury?
J.
M. O'Neill, J. S. Runnels
and L. E. McPherson;
Attys. for Deft. Co. |
...
Jan 22nd 1889
Cross Interrogatory the 1st.
If you have answered that you were
keeping the Hotel Coronado - state how many guests stayed with
you during said time and if you remember the names and physical
conditions of them all while with you - did you examine Mrs.
Wilson's wounds if so on what part of her body were they?
2nd
What business or occupation are
you now following and what were you engaged in before you took
charge of above named Hotel?
DeArmound
&
Ball Wynne & McCart
Atty for plaintiff |
_______
In
the Circuit Court of the United States.
For the Northern District of Texas at Dallas. |
ANNIE
WILSON
vs.
THE PULLMAN PALACE CAR
COMPANY. |
}
}
} |
No. [blank] |
State
of Illinois }
Conty of Cook. } SS. |
By
authority of the stipulation of counsel in the above entitled
cause, said stipulation, dated January 22nd, 1889, being hereto
annexed, and the interrogatories accompanying the same, likewise
hereto attached, said cause being now pending in the Circuit
Court of the United States for the Northern District of Texas
at Dallas, I caused to come before me, at my office, in the city
of Chicago, County of Cook, and State of Illinois, the witness,
J. B. Seghers, therein named, a resident of the County of Cook
and State of Illinois, aged thirty-seven, who being by me duly
sworn to speak the truth, the whole truth and nothing but the
truth, in answer to the several interrogatories and cross interrogatories
in the said cause propounded to him, proceeded to answer the
same, as follows:-
Int. 1st. State your name,
age and place of residence and occupation?.
In answer to Int. 1st., witness
says: J. B. Seghers. Age 37. Place of residence 30
29 Vernon Avenue. Not in any business at present.
Int. 2nd. This is a suit brought by Mrs. Annie Wilson to
recover damages for an injury she alleges she sustained by falling
from a ladder, while she was endeavoring to climb into an upper
birth (sic) on one of the cars of the defendants, the Pullman
Palace Car Co. on or about the 21st day of February 1888, between
Colton and San Diego. She alleges in her petition that by reason
of the breaking of the step ladder and her fall therefrom, she
received injuries which caused her great and excruciating pain
and suffering of body and mind, and does and will continue to
do so as long as she lives. Do you know the plaintiff,
Annie Wilson? When, where and under what circumstances
did you know her?
In answer to interrogatory
2nd., witness says:
A: I knew the plaintiff,
Annie Wilson, as a guest of the hotel that I was manager of,
the hotel Del Coronado, Coronado Beach, San Diego, California.
She arrived at the house on the 24th day of February, 1888,
and it was there that I knew her as a guest of the hotel.
Int. 3rd. If in answer
to the preceding interrogatory you say she came as a guest to
the hotel Coronado, in San Diego, then state when she came there,
how long she remained and when and under what circumstances she
left? State how and why you know this?
In answer to interrogatory
3rd., witness says:
A: She came there February
24th, 1888. She remained until the 2nd day of March, 1888.
She left on the 2nd day of March, 1888. The circumstances
were nothing that I know of in particular, she left of her own
accord, so far as I know. I know it as being manager of
the hotel.
Int. 4th. Who was keeping
this hotel at this time? If you say you were, and that
Mrs. Annie Wilson, the plaintiff, was a guest in said hotel in
the latter part of February 1888, then state fully what complaints,
if any, were made by the said Mrs. Annie Wilson, during her stay
there, as to any bodily injury, or as to any suffering either
physical or mental, arising from any bodily injury, or signs
thereof you observed her to have, and state your opportunities
for observation?
In answer to Int. 4th., the
witness says:
A: It was owned by the
Coronado Beach Company, but it was managed by me. There
were no complaints made by Mrs. Annie Wilson in regard to any
physical or mental suffering during her stay there, so far as
I know. As a manager of the house it was my duty to be
among the guests, and I saw her each day in going into the dining
room, going out on the motor to San Diego, and saw her in the
ball room, and on the balcony in the evening during concerts.
Int. 5th. State, if,
you know, what parties, places of amusement or public gatherings,
if any, Mrs. Annie Wilson attended during her stay at your hotel?
State what part, if any, the said Mrs. Wilson took in these festivities,
if any such there were. What was her condition, as far
as you could observe, as to suffering either physical pain or
mental anguish on account of any bodily injury?
In answer to Int. 5th., the
witness says:
A: I saw her at two balls
at our house during the period of her stay there between February
24th, 1888 and March 2nd, 1888, in full dress, unattended. She
walked across that ball room, 120 feet in diameter, without any
signs of lameness or indications of physical suffering whatever.
She took no part in the festivities, otherwise than as
I have already stated, that I know of. As far as I could
observe, she did not, on those occasions, show that she was suffering
bodily pain or mental anguish.
CROSS INTERROGATORY the 1st.
If
you have answered that you were keeping the hotel Coronado, state
how many guest[s] stopped [stayed] with you during said time,
and if you remember the names and physical condition of them
all while with you? Did you examine Mrs. Wilson's wounds?
If so, on what part of her body were they?
In answer to Cross Int. 1st.,
the witness says:
A: There were in the
neighborhood of 315 guests at the hotel Del Coronado from February
24th, 1888 to March 2nd, 1888. I can remember the names
of a great many of them, but not all of them, and know pretty
well the physical condition of most of them. I took
particular notice of Mrs. Annie Wilson on account of her loudness
of dress. I saw a number of young men visit her
apartments, and because of this, and because of reports derogatory
to her character reaching me, I had determined to ask her to
leave the house, when she saved me this necessity by leaving
herself. I did not examine Mrs. Wilson's wounds.
X 2nd.
What
business or occupation are you now following, and what were you
engaged in before you took charge of above named hotel.?
In answer to X 2nd., the witness
says:
A: I am doing nothing
now particularly, and I was, before taking charge of the hotel
Del Coronado, Manager of the Union League Club, Chicago, for
over six years.
J. B. Seghers /s/
Notary fees pd. by deft. $6.75
Witness " "
" " 1.00
" "
" " "
.30
$8.05
J.
C. F.
Which
answers I cause to be reduced to writing, and they were sworn
to and subscribed before me at my office in the City of Chicago,
County of Cook and State of Illinois, aforesaid, on this 4th
day of February, A. D. 1889 by the said J. B. Seghers.
IN WITNESS WHEREOF I have hereunto set my hand and official
seal this 4th day of February, A. D. 1889.
J. C. Finch /s/
Notary Public, Cook County, Illinois. |
...
In the Circuit Court of the United
States.
For the Northern District of Texas at Dallas.
ANNIE
WILSON
vs.
THE PULLMAN PALACE CAR
COMPANY. |
}
}
} |
No. [blank] |
State
of Illinois }
Conty of Cook. } SS. |
By
authority of the stipulation of counsel in the above entitled
cause, said stipulation, dated January 22nd, 1889, being hereto
attached, and the interrogatories accompanying the same, likewise
hereto atached, said cause being now pending in the Circuit Court
of the United States for the Northern District of Texas, at Dallas,
I caused to come before me, at 3029 Vernon Avenue, in the City
of Chicago, County of cook and State of Illinois, the witness,
Mrs. J. B. Seghers, therein named, a resident of the County of
Cook and State of Illinois, aged twenty-six, who, being by me
duly sworn to speak the truth, the whole truth and nothing but
the truth, in answer to the several interrogatories and cross-interrogatories
propounded to her in said cause, proceeded to answer the same,
as follows:-
Int. 1st. State your
name, age and place of residence and occupation?
In answer to Int. 1st., witness
says:
A: Mrs. J. B. Seghers.
Age 26. Place of residence 3029 Vernon Avenue, Chicago.
Occupation, keeping house.
Int. 2nd. This is a suit
brought by Mrs. Annie Wilson to recover damages for an injury
she alleges she sustained by falling from a ladder while she
was endeavoring to climb into an upper berth on one of the cars
of the defendant, the Pullman Palace Car Company on or about
the 21st day of February, 1888, between Colton and San Diego.
She alleges in her petition that by reason of the breaking
of the step ladder and her fall therefrom, she received injuries
which caused her great and excruciating pain and suffering of
body and mind, and does and will continue to do so as long as
she lives. Do you know the plaintiff, Annie Wilson? When,
where and under what circumstances did you know her?
In answer to Int. 2nd., witness
says:
A: I knew who Mrs. Wilson
was. I knew her by sight, but not to speak to her. Mrs.
Wilson was a guest at the hotel Del Coronado, arriving there
about the 24th of February, 1888; at that time I was acting as
housekeeper of the hotel, and I met Mrs. Wilson very frequently,
during her stay, in different parts of the hotel.
Int. 3rd. If in answer
to the preceding interrogatory you say she came as a guest to
the hotel Del Coronado, in San Diego, then state when she came
there, how long she remained, and when and under what circumstances
she left? State how and why you know this?
In answer to Int. 3rd., witness
says:
A: Mrs. Wilson was at
the hotel for about a week after February 24th, 1888, and, after
leaving the hotel, I met her several times on the boat going
from Coronado to San Diego. As housekeeper at that time
I knew of her being there as a guest. I don't know anything
of the circumstances attending her leaving the hotel.
Int. 4th. Who was keeping
the hotel at this time? If you say that you were, and that
Mrs. Annie Wilson, the plaintiff, was a guest in said hotel in
the latter part of February, 1888, then state fully what complaints,
if any, were made by the said Mrs. Annie Wilson during her stay
there, as to any bodily injury, or as to any suffering either
physical or mental, arising from any bodily injury, or signs
thereof you observed her to have, and state your opportunities
for observation?
In answer to Int. 4th., witness
says:
A: The Coronado Beach
Company; Mr. Seghers was general manager there. I never
heard Mrs. Wilson make any complaints of any suffering either
physical or mental. My opportunities for observation were
the very best, because, as housekeeper, my duties led me very
frequently into all parts of the house.
Int. 5th. State, if you
know, what parties, places of amusement or public gatherings,
if any, Mrs. Annie Wilson attended during her stay at your hotel?
State, what part, if any, the said Mrs. Wilson took in
these festivities, if any such there were. What was her
condition, as far as you could observe, as to suffering either
physical pain, or mental anguish on account of any bodily injury?
In answer to Int. 5th., witness
says:
A: I saw her at two balls,
and also at the concerts given in the evening. She never took
any part in these festivities, as far as I know; she came in
alone and went out alone. During the time of her stay there
I saw her walking up and downstairs several times; as far as
I could observe, she was not suffering at all.
Cross Int. 1st.
If you have answered that you were
keeping the hotel Coronado, state how many guests stopped with
you during said time, and if you remember the names and physical
condition of them all while with you? Did you examine Mrs. Wilson's
wounds? If so, on what part of her body were they?
In answer to Cross Interrogatory
1st., witness says:
A: I don't know how many
guests there were at the hotel at that time. I do remember the
names of many of the guests at that time; as housekeeper I came
frequently in contact with them. I remember the physical
condition of nearly all of the ladies who were guests of the
hotel at that time. I never examined Mrs. Wilson's wounds.
Cross Int. 2nd. What
business or occupation are you now following, and what were you
engaged in before you took charge of above named hotel?
In answer to Cross Int. 2nd.,
witness says:
A: Keeping house for
my husband and four daughters. Before acting as housekeeper
of the hotel Del Coronado, during the time mentioned, I was not
employed at all.
Mrs.
J. B. Seghers
Which
answers I cause to be reduced to writing, and they were sworn
to and subscribed to before me at my office No. 3029, Vernon
Avenue in the city of Chicago, County of Cook and State of Illinois,
aforesaid, on this 4th day of February, A. D. 1889 by the said
Mrs. J. B. Seghers.
IN WITNESS WHEREOF, I have hereunto set my hand and official
seal this 4th day of February, A. D. 1889.
J. C. Finch /s/
Notary Public, Cook County, Illinois. |
Notary fees pd. by deft. $6.75
Witness " " "
" 1.00
$7.75
J.
C. F.
...
|
