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HomeMy WebLinkAboutRailroad Records 1893-18951893 3 - 1895 - “| North Carolina. — : Superior Court, Iredell County. ae en O.W. Lawson VSe The Richmond &« Danville. F.R.Co. ,and the Western North Carolina RaRs Companys Qase on Appenl. This case was heard before his Honor Boykin, Judge, at the August term,1992,of the Superior Court of Iredell County,on a motion by the Defendant,the R.& D.R.R.Co.e,to sign the following order,to wit: "North Carolina. Superior Court. Iredell County. O.W. Lawson V8e The Richmond & Danville R.R. Oo. , and the West w > . In this case,it appearing to the Court that the Defendant,the R.& D.R.R.Oo.,has obtained an order for the re- moval of this oanuse into the Circnit Court of the United States for the Western District of North Carolina,all of which appears from the petition,affidavits and bond of said Defendant and the order of said Court duly certified to this Court,it is considered and adjudged that this Court will pro- oeed no further in this cause,and that the Clerk of this Court dertify to said Cirouit Court before the next term thereof a copy of the record in this canse.* This motion was founded upon the petition,affida- vits and bond of said Defendant and order of the Cironit Court of the United States for the Western District of North Garolina, certified copies of which were filed in this Court, ' and are a part of,the reeerd in this catise,a certified copy a of whioh the Clerk of this court will send up as a part of this case on appealyfrne Court declined to sign the order,and made the following entry on the docket,to wit: “Fhe Court. de= clines to permit the removal of this cause to the Circnit Court of the United States,and declines to sign the order presented by the Defendants. "dina from this judgment the Defendant,the R.* D.R.R.Co. ,appealed to the Supreme Court of North Carolina. Notice waived. Appeal bond in the sim of twenty-five dollars adjudged sufficient. \ de ot ctf wobh leche abherve OCzee- On aX feat ttakerck h he r tei hae ki Ate A n/ Aah oh bar e hake pok eke oY natal, Kah she J 2zat C VesLaurta/ A “ed Ag OUAMLL be Le oN at; Ae. oh. AYP CA Od. ~ ars ALys4ta Mr An ty bey ——\_—" fury 9 (4s AWN eho DN 0 Xx J “TO a i= era rer n 4 bw POREG > BOT Stperioer: Court? °°: Ft —— pees) er o ove, gore a” bid Me Roy x a ths Ereecks ‘ = Ps ‘ - ¥ - om « . . ? a ae i +> 4 22 OBi2< yet wre the ‘Rigbisond ana Dangilie Railroad Company. fer Answer 1 tue Co Yejat in a Set =P: pets SR» 3% +o ~ Pte - LH iw this case says~ ~~ -~ ~¥ * ; ¢ « ‘ ZN OLE fuk sg wa a cs J wont a= £8 ~- by c@sec* tte cay orezle c8 7 Porep in: Frat <i-4n anSyer to siete: No 1 it says It ‘sas Lb @ »¥, ts that the W. M. C, R R. nad th¢ deruila ties fers o the gre Co. - isa corporation arganiaad ander. the Taos at North eds and that. ‘te: R. A ?. k R. Co, isa cor poretian organized under the laws of the State of Virginis apd is doing business in North Carolina and that it is “the lessee of tue Western Worth Carolina Railroad Company. a Rerth "ersiias 2 tea suer to allegation No 2 this defendant says, it admits that it was fiom CE SIGS & Common Carrier of pessengers on the Ww, N. Ce kK a. on the 27th day of Au soreéCReias Loele Bobs °8) t9eakers apm £6bGs A eeeprios cnet oem, Lae htt Recta tae eet to: wVa Gefendant was « common Carrier of passanears at that time or for some - Bay's ar cae 2°96 te0se tat 236° be be) , Sie previous thereta, the said ¥. x. 6 RR Sompany haying leased, its ~ Bhabha es.such, to this defendant. n Ae cy te A 5 It démits allegation No 3 to wit thet plaintiff was a passenger am its train from Stateswille.to Newton. Saco ta as re 77 7 ee. LY J C"tHtS LEC LEE Ce o atts ¢ ae speed ee oP , Si oh i #4 In reply to ‘ellegation No 4 it says .It adatts that its train had to pas gee eS 7 adnate 4isauat about %5 or 80 feet ee ae Bostian’s bridge > hee ws) asles pet. of Statesville, It admits tht tte train was de- ve 68 rr brown fro iis: track very near. tp,and sas! 3 this vieduot “aad that, Plaintitr rece! ved persons). dajuries. from said derailaent, to = attest ‘extend this: ‘defendant doss not know, Tis defendant denies emphat~' fealty the other allegat tion ap this paragraph and: ‘eapecialty the negli-’ or eky Abarat set. out, : .-e =. Oo ; 6 This défendant arore upan information and belief.that some person or | persona, at this tine unknown te: thtg alefendants unioke dly,. ‘de Signedly anid . wengf wi Ly *oek up end displaced one of the rails of its track and there-' by catised the deplorable catastrophe mentboned in Plaintiff’s complaint -5 and the ate ret lust ol ue fende nt’ s trate ast tie grevious personal injuries ~ Daecedwed bythe: pla taiitr. See A imeniettinich TA4 Se LS Ct aalse- anes) Fér th Careclt | _ ott le @bpmommbly appeared before We 42 Bs dridress’: who bathg or tee pqemant & Beertiie Ratiresd tet ‘on rete aot SRR xuewes: of Wis off Khow)~ wmGge:- are true and-those stated upon information We velieves to be true dive previeht therctc . Oart : i” b vVLS. 2 aie Swora to amd subseribed before we this S74 day of 1891. itng , 1) Bich. 2% low eitt. et eae LM Behe te-/ Prrek | | | hil Boos Covcyo — cectere atest bon ptoet pS Ny tage: | BC th. Me . Aviat Beith : | Ciuc Ong here! Hu. t ana gracel. off all oh. h-% ff £ ae QA Onn rn/ Cori, orth Se dag af Apt 1686, ck tne) eek Cretan n/ Rat Bond ate Ets Ce os an fait AtaitAonl ¥ ie Mofo ct at Air S hat cf % te eraw eX, at aoe a Peg 4 oft Epa fal pty dnc, che eugene Be 375 cy alia a bhih rtfen/ ee oe ie Orrabie/ Aad An Me aswell. eal tf 9 . ie ro | ite: fb eal oe l Cebe 4h Pci on Vy thin!’ ik g * fot to Slt tr aMsl aa ary Me me, he J/, Mage 1 heacek Leer. We 1H Aldory Diets OicicSDy J rd i ; ai a LY tits 00 tae Bt 7 fA ss $e Pos ee .¥ » > fr Superior; court, re November: Tei, 1891. SB oe Oh Sosebvsbigtas i e o o a “The fi dha andbenv i216 Pa a ‘ ,~ Rr oe cg a ee Ske ees _ Railroad: Company: and The “Affidavit e ) " Western North Caroline, 4: Ke PRONE D eae i Railroad conan. ae *, ; s Je Le shales: eg sworn. ceaneiine to tIaw eaye: 2/That he is the. ‘Agent of the Richmond and Danville Railroad Company, at Statesville, North Caroling. 2.That he is ngt. the Agent oF the Western North Qarolina Railroad Company. and has not been such for eoveral years sdat. That he is not in the ais Veuatas of the Western North Carolina Railroad te pany, and has not beeg,in any capacity, for several years past. Sworn to and’ subseribed be~- ) fore me this 13th November, ) 1891. ) Whee oO Clerk Papenror Court. —— -* Nes tracmievoi’ > ' . ! . t pe ! e 1 rrolrety: : ¢ Sill Lows ' & of . re ca Q ~ we ( f { etivabitrtaA ( ( { ( t Tig Cree i _ a . ~ 3% —— ee me eee ee et eee ; 2 eflivaedebns ba . ef? bas vaeqmol beorlial siutforse) ddvroll mpretnae’ -¥neqmooD bsorl ist tevee wet of xantbrooos mrowe anied ,aefroe «Tt «% -vapaqmod beor(ted offftvast bas baomilold ext to snepA.ent ei ed tsdt.1 -enitiored diroll ,ef{iIveetsaie ta vt beoviire" entioreD dro | mretes d+ to tnenA ent tom ef eri tendt’.S er of seri? -tesq erney Lr ove ro. sone meed Jon sari € emo> bsaorf{re” anftlore) five cfroteoW erit to smenrvoltqme er teed err: [evovee rol , sroeqso yne al,good ton gas brie -od bedivsedive base of mow? ot! ovoll dséiLl atnt om orro'l efeei IN THE CIRCUIT COURT OF THE UNITED STATES ve | Western District of North Carolina. against Petition for Removal. To the Honorable, the Judges of the Circuit Court of the United States, for the Western District of North Carolina: Your petitioner respectfully shows es, Ko suit entitled as above is now pending for trial and has not yet been tried in the Superior Court of 4A+444.—__. County State of North Carolina; and that your petitioner desires to remove the same into the Circuit Court of thd United States, for the said District. That your petitioner is one of the defendants in said suit, and that the matter and amount in dispute therein exceeds, exclusive of interest and costs, the sum or value of two 0 dollars, and .the same is to recover damages for the alleged negligent... ones Fs operated in the said State of North Carolina, the same having been leased to petitioner, which was wholly operating the same at the time of the dewehmef A Recrrgprcmctin ect tte ie ad # = 5 ae en And that your petitioner and the said plaintiff are actually interested in said , controversy. That said suit was brought for the purpose of recovering damages as atoresaid fi Be. : 3 ‘ Op ¢ ‘ Bhp eh Lgl my ne at hg bik he hee Re ew ee re men: by reason of the alleged negligence of the said petttyéyers servants, the said petitioner operating as aforesaid the said railroad, upon which the said.\/< » Se iranian was being carried as a passenger. That, as your petitioner is informed and believes, the Western North Carolina Railroad Company, a defendant in this suit, was made a party to prevent a removal of the same to the United States Circuit Court for the said District. That, as your petitioner is informed and believes, the said Western North Carolina Railroad Com- pany is not a necessary party to the said suit, being in no way connected with the operation of the rail- road, having leased the same to the petitioner in the year 1886. That the defendant, the Western North Carolina Railroad Company, is not engaged in the business of a common carrier in the State of North Carolina, as is alleged in the complaint of the plaintiff filed in this suit. i That this said suit was begun in the said State Court on the...4. Oe a in ta ienen ASG) nnaiiacatarcastesmsnpasernncestintipsi ae and has not stood for trial at any term of the State Court since it was begun, as your petitioner is in- formed and believes. Your petitioner further states that he has filed herewith an affidavit that it may be made to appear to the said Circuit Court, from prejudice and local influence, your petitioner will not be able to obtain justice in said State Court, or in any other State Court to which your petitioner may, under the laws of the State of North Carolina, have the right on account of ‘such prejudice and local influence, to remove said cause. Your petitioner therefore, prays that the said affidavit may be accepted as good and sufficient, and that the said suit may be removed into the said Circuit Court of the United States for the said District, and further, that your petitioner be granted such orders in the pgemises as it jg in law entitled to, to se- cure the removal prayed for. , VFA Attorney for Petitioner. . ae . being duly sworn, do say, that I am an Attor- ney for the petitioner in the above entitled cause; that I have read the foregoing petition, an allegations made therein are true, except as to those made on informatiga and belief, and Ahose, I be- lieve to be true. s ‘ } Attorney for Petitioner. in my presence, and by iK U.S. COURT. | IN THE CIRCUIT COURT OF THE UNITED STATES Western District of North Carolina. ~ A eS oe A : . eo eines btaihd acliebea pebeibigns aiale dips teresa beens dor natisiniekeeaictiad orb bla oeialaden a atiakoee wcuiee saad nc ameaesiies Vas tn ; 8 eo qe" + 4 on. AL. for Removal of Cause. Le-F AA Veto a x aac Mf AO LAN. i Sworn do say that the Richmond and Danw e above entitled <<... County, in the ial in the Superior Court of _.2/44-<#>.<S-5== State of North Carolina, and that from prejudice and local influence the said defendant shall not be able to obtain justice in the said State Court, nor in any other State Court to which the said defendant may, under the laws of the said State of North Carolina, have the right, on account of such prejudice or local influence, to remove said cause: that by the accident which occurred on the railroad of, this defendant on the 26th day of August, 1891, and which is the basis of this action, a number of persons, passengers and employees on the train of the said defendant were either killed or wounded, as many as twenty-two being killed, or having died from injuries received, and about twenty-seven injured, and that the said accident was at a place called Bostian Bridge, in the County of Iredell, in said State, on the date above mentioned; that the report of said accident was at once widely circulated, and many persons from the County of Iredell came to witness the scene of the accident and also many persons from the adjoining Counties to Iredell: that the dead and wounded were carried to Statesville, the County site of Iredell County, where the dead bodies were viewed by numerous citizens from the locality, and where many of the wounded were taken into the houses of citizens of said town: that great indignation was expressed by numbers of persons in the community on account of the great loss of life and injuries resulting from the accident, and many harsh and unjust criticisms were made upon the said defendant and the alleged careless manner in which it had operated its said railroad: many leading citizens going so far as to charge publicly that the destruction of | fe and injuries to the persons was the result of the recklessness of the said defendant and its wanton disregard of human safety and human life: that a newspaper pub- lished in Statesville called the Landmark, generally circulated in the County of Iredell and circulating also widely in the Counties and localities adjoining and around Iredell County, which said newspaper has great influence in its circulation, published articles adverse to the said defendant on account of said accident, bitterly arraying the defendant before the readers of said paper and the public on account of the said accident, whereby, and on account of which much prejudice was aroused against the said de- fendant and which still exists: that many of the persons killed or injured in the said accident were res- idents of the said County of Iredell and the adjoining Counties where their families, relatives, friends and associates reside, all of whom are, or have been active and zealus in denouncing and criticising the said defendant and exciting against the defendant much ill and prejudicial feeling: that other newspa- pers than the Landmark above named published and circulated in North Carolina and in the County aforesaid and the adjoining Counties have published and circulated articles bitterly denouncing the said defendant on account of the said accident, using such expressions as rotten sills, loose rails, negligent employees and other like expressions to convey to the public the impression that the said accident was due to the gross ‘and inexcusable negligence of the said defendant that by reason of these things a strong public sentiment, prejudicial to the defendant, has been manufactured and matured so much so that this affiant verily believes that the said defendant cannot obtain justice in the State Courts aforesaid: that anumber of suits have been brought in the State Courts of North Carolina upon the alleged cause of action aforesaid, there being as many as twelve or fifteen in the County of Iredell, as many as ten in the county of Buncombe and several in other Counties, and affant is informed and be- lieves that the parties plaintiff have made common cause in all the cases, and that they and their friends have been active in prejudicing the public mind against the said defendant with a view of placing it at a disadvantage in trials of said causes in the Sue CG. tov bed by the + Noes f peed tnt pesssese . in my presence, and by before me, this... =a asin day of-—A-4+. .., 1892. _ AUG 4 1999 = Oo. COMTLES ‘CLERK U. S.¢ URT. Kym all men by these Presents: ric. Aone, i) Mite cris money of the United States; for the payment of which, well and truly to be made, we bind ourselves jointly and severally firmly by these presents. The condition of the above obligation is such that it Lae. tu. AeA TUR cassie of North Carolina, on the first day o then next session, a copy of the record in a certain suit now pending in the Superior Court of Redadiie County, State of North Carolina, in which 20000 eeeeeeeeee ee is Plaintiff and — : Defendants; and shall pay all costs that may be awarded by the said Circuit Court, if“said Couft shall hold that said suit was wrongfully or improperly removed thereto, and shall do such other appropriate acts as, by act of Congress, in that behalf, are required to be done upon the removal of such suit from said State Court into the said United States Court, then this obligation to be void, otherwise of force. n_ek 135 2 Apmrord © 1 Miran entad le EL. Pmt.. ee® [SEAL.] ; 2 te eee | Fe 7 AMAL Her Nese [SEAL.] [SEAL] Dated this..... pa day of.> INA, County.. STATE OF NORTH CARO County, the surety named in the foregoing Bond, being duly sworn, do depose and say that I am a resident of the State of North Carolina and a property-holder therein; that my debts and liabilities, and exclusive lam worth the sum of Five Hundred Dollars, over and above roperty in the State of North Carolina liable Ate. “tromdred dollars ,. Subscribed in my presence bite MAKE LP Dy cc ra wie tow nd by oh eile ‘Eike 87 - of property by law exempt §f to execution of the value o ~~ yorn to before me this... se day of Ato: Oe ew ee en ewan n wn ne ieee VS. .....- County, N. C. BOND FOR REMOVAL TO THE U. S. CIRCUIT COURT. D. SCHENCK, Attorney. ‘ OP en IN THR CLROUIT COURT OF THE UNITED STATES Western District of North Carolinas Fourth Ciroulte . | O.W.Lawson, Plaintiffs Against , Order. — ” ‘Tne Richwond and Danville Railroad cline fallroad Cogaay: Defendants. reading the petition end affidavit filed in this causa, and upon eensideration of the seme, together with the hond filed and all the same being eufficient in lew, ond in due form, and it having bean made to eppear to the Court that on agcount ef Joss) influence and prejudice, the petitioner wil) not be able to obtain justice in the State Court as set out in the petition and affidavit, nor in any other State Court, to whieh petitioner would have the right to ramve the said cause for trial; it is eansidered and adjudged that the said loeal influence and prejudice do exist as set out in said petition and affidavit. It is further considered ané adjudged that the said petition, affidavit and bond be aceapted, and that the above entitl ed eause now pending in the Superior Court of lrede)) County, in the State of Morth Carolina, be removed into the Cireuit Court of the United States, for the Wesiem District of North Caro] ina, for trial. And it is further ordered that the Clerk of this Court, at Statesville, North Carolina, @ certify this order, w the said Superior Court, together with a oopy of the petition, affidavit, and bond, to the end that the said * sat ay SER Mics « Roe iy Superior Court may proceed no further with the oause} end to the end, futher, that the said Superior Court may | make.a full and perfect branseript of the reeord and |" pxeeeadings had in said case, to be trananitted to and filed “dn this Gourte — ? ‘ ‘ Hugh lb. Bond, Cr, Judge. | rane ae _Unkted States +. eae Ameria. _. Western Distriet of North Girel Seco 3 I, HeGeCowles Clerk of the Cireuit Court of the Uni ted i2 9 tckes in and tor. maid Matriat at Statesville, M.Cs,. do re- Caeby certify wafertexqoing to be a full, true end perfect ae of the petition, davit, bond and erder made and Bn in the ease ee a eer nst the Richmond and Danville Railroad Company and xa Wectern North Carolina Railroad Company. | qm fully os the same remains on file amd of résord in said 6ause in my office. In witness whereof I hereunto subscribe my nemo and affix the sea) of said court, Hyetiow in Statesville, in said District this the “tiny t 1802. “Work of said Court. AUG” 4 1899 So cowin1zs CLERK U.S. COURT. é { 4 Commission to take Deposition.—Printed and for sale at Tas LanpMark Jos ee plat at N ORTH CAROLINA, THE STATE OF NORTH CAROLINA TO _/7: WA Veaetls évo, .. GREETING: DCF be Beaks Afr? In the Superior Court. We reposing special trust and confidence in your integrity, do authorize and empower you to we appear wenn you at such time and place as you may appoint, and.. | 2 | Fans to examine touching all such matters and things as Bhall know of and concerning a certain matter of controversy ig our Superior Court — county pending, wherein plaintiff, and. aT Cosh FE anadtt Rastand Leet C4 Vicen ae. “4. Fikes, “deh vr defendanté And the deposition in writing, by you so taken, the same to tranamit, sealed with your seal, to our “es “/ Superior Court, to be held for said county, on the..4& M2 den day. bifers. hoe Abend ag. me Nahe lnd. 7894 Pecceetumuananiecns seseeeneeeessenseeesceeceeeeeceeeesy Olork Of the said Oourt. a la ~ i el, : 7 | Ld71872 at of ec o/ I ty hb, ae ok. Grew ethh, C4KP Beak tie | ...; SUR diseind Gieniniel es Std rae Oprrrinecicone tae nal, ome, mA AE olay of fol, ea Ee vee me eae Fencsentts © feo fs a past endow Bip rm ach a pe oe Be eon ieee Spe ct oe pm ie aed gow Fen . oe ee i wok ; x * on = a ae eR Attn ‘ > ~ t a« 7% r a RS Angad , Mim mK het ot pbk, Goo odes . py Cen Pe een A ts kiog eS ‘ , ‘. ah eee ee pee nn OREM SF ON Cte a . i Kuow all men by these Presents: tha we Luc Lacon arancter bo as surety are hereby held and firmly bound unto a ee be iasskio cuss saissaeinlomuiake aes in the penal sum of Five Hundred Dollars, lawful money of the United States,-for the payment of which, well and truly to be made. we bind ourselves jointly and severally firmly by these presents. The condition of the above obligation is such that if Lhe Meaceerstrcei- te Af zee — shall enter and file, or cause to be filed, in the next Circuit Court of the United States for the... ei ee i a patos cate Nes i a he ee ge District of North Carolina, on the first day of its then next session, a copy of the record in a certain suit now pending in the Superior Court of ee County, State of North Carolina, in which ..... | QE PAPA PRL... piace es Satins <: deakendhaenh sag than bad dace tease ligtliie na lig Nate td, a nn, | ie denigieitalnisithadinen helen caeesinieanserjephisbtindlnesbapeabinielisiineniecchgtipasesanabochassdemnstiinnitiscenasioepipinostbccines nn ht..ewveDefendanty and shall pay all costs that may be awarded by the said Circuit Court, if said Court shall hold that said suit was wrongfully or improperly removed thereto, and shall do such other appropriate acts as, by act of Congress, in that behalf, are required to be done upon the removal of such suit from said State Court into the said United States Court, then this obligation to be void, otherwise of force. Dated bese day of...... Midi dapiniielh sin Buieca 18F/Z... Sige fr Luling feeh, AM. sear} ae gee ROLINA, County. _ .. a . = ee es of... Giathen. . , County, the surety named in the foregoing Bond, being duly sworn, do depose and say that I am a resident of the State of North Carolina and a property-holder therein; that I am worth the sum of Five HundrethDotlars; over and above all my debts and tiabitities; aid exclusive of property by law exempt from execution; that I have property in the State of North Carolina liable to execution of the value of I a i8 Sap I oe hundred dollars Subscribed in my presénte-by.... MAD... kA Bac Arlt Act rrr, and by 7 him swoftn to before me this........4.......day of ......- County, N. C. E ‘BOND FOR REMOVAL TO THE U. S. CIRCUIT COURT. D. SCHENCK, Attorney. — ee al ~ \ County, North Carolina: District of North Carolina. te To the said Superior Court: ~ (1) Your petitioner respectfully shows to this Honorable Court that ‘the matter and amount in dis- . a ei eon ncaa A ACL LA LEO OA pute, in the above entitled suit, exceeds, exclusive of interest and costs, the sum or value of two thou- sand dollars. (2) That the sonfyoversy i in said spi is between sitiseus of diffgrent States, and that the Petitioner was, at th e time of ms commencement of this suit, and still is, a citizen of the State of (3) Your Petitioner further shows that in said suit above mentioned there is a controversy which is wholly between citizens of different States, and which can be fully determined as between them, to- wit: a controversy between the said Petitioner, the lichen | Miticicaasaditen. Memento, , aand the said inches cere Scns tpcantiahap ilies distendindbcan debuassinieteesbiandctinig: aitnaionive sabiak Neda Bii witel cic And your Petitioner offers herewith a bond with good and sufficient surety for his entering in said court of the United States, on the first day of its next session, a copy of the record in this suit, and for pay- ing all costs that may be awarded by said Circuit Court, if said Court shall hold that this suit was wrongfully or improperly removed thereto, and for performing any other duty required in the premises by law. And your Petitioner prays this Court to proceed no further herein, except to make the order of re- Jngya! required by law, and to accept the surety and bond, and to cause the record herein to be re- moved into said Circuit Court of the United States in and for the .. District of —“__ww81. and Petitioner - Attorney for Petitions 4 & .. being duly sworn, do say that I am the Attorney lor the Petitioner in the above entitled cause; that I have read the foregoing petition, and know the ¢ontents thereof; and that the statements and allggations therein contained are true as I verily be- lieve. : Subscribed by the said....... eee presence and by him sworn to before me,’ | Act March 3, 1887. ee hr hett.. County, ¥e att Term, 1p / | EMATCE Lemna, | Petitioner. i F PLe!I Lib {PPO 42 22-76 ZA Attorney. (Act of March 3, 1887 a5 : 197 aia. Rabioe) Cocuphe. Wuwbrc tr Gactinn Quivers Brnsfpary \ nh 2d A Afefeigicg bh Dual, fala; fea frre Omforremisd Fo F One ewend Betton, . oe ae pp ti cat 2 al ae ed Co. e iz wy Ch Qarslhia Ce, Sas. gee ns Gf Bhan Boy il L KH ar Bro (SVE af wp. Mer fleeing he tofu danX Th Arb RR}: & ac9g>— te Sacre cxig ae oe VJerTK Qarrhinn Ps ccteet Oren t, F hes. 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Tn hrewwrnsh ancrtBhacdingr ait ath vol Cra fang rag os he €or aie bd» ww or att Ti 27 cLa, /€@C Ws aaice Bgerrark & FE Prva ed aS Bauntg Rorit-radt ms Loser fe. me Dol, ~Le r Der Zr Ait rnfawr, , & Com a pp Nev Bas , ate DK, pix hare, OGfA aren, ated ertset relay 1 Zeer fae nt pmal att oft. f$r-~f--2 }- Rote Cor Liew mctetne. preres Lo -F- 7 g 2 nt, potatos Rita S regie Lewol Accor Fic te Cac 5 0 Coreen 9 Pre Bde ee or peti es ig hte i BA AE AOR AERP AN a A i — ont ft» rg ts we the uk da, q for SEPL anr€ el ant sence ead tat, od a (aac rth Hos: oe a ee eee av aot. Eo Cot 1s Sid PSs: f Pc Binley a rs Vay Liew oil fa Gr end: Cece g, | (en Leht, a. > la Loony 24. | Bee. ee “aloe od otha orp Paco flac - fet Conn Lone, yee flninchitt, fore of weed a Sell diss on Loved (Loi Ko Dal, ite | SV 4 (Lait - (Cra 3G ri~ faz ct ces Manirle Ware i fool | ae my AS <~— gp ee Meee FT os call a ¥ wax«d k= - nz i. Carte, Tm Le Sane z — aw o r pia. we Rapewack poatt atts pee La~<e femie, LL or AAS is : wie cf yor GA aoe Landa, awd agZ, Cet fla. 2¢¢ ow a Jardin san an Tee an +t, ony a=-29Y Slo ans as + Lahnas 0 : lst and mig. : Ze Be Sn hog ee alethlive mile mek 4S ee his oo in ace « Pome fa ao. ~ yg can oman & eel D yt he eee ghee” Oh ae me yes. 1 P= Shot phav Lgg tine nice ee Se : | | ef ¢ _ eee Ree a a. fmrinnigtg lo-~. Oyen Sa—Z aA, fas Se cea, whapiy 4 Lega og Site Qo oe ev HZ 2 4a. Fach, prt wear aehiyhees & Coe or | eS i Pe mg a. diese oeee Af. ~ Jaz Caw caniseml (Cai igg forme Ampere L of tere, ae Prcarinere of Cohan Ze hic aK 5-4 Aine KL Rope - Gennes, TH sich Har, Ch prok Jasia Gen. ep lel Menard ts 40 ~ a Phe for Ce Pingel x tt sn Be. at = 42 Aor ok 0th ns fp Dh. > hig 18 voip Kaa ro ol JIscete____ Ally, foe fo Big 0.9.9 fom a NF Ma ay = a, JE pau. = ORFS plies Ge" Qe fe Lorna afore ; a a Be y ats of the nt ) Whe, oe A Ley Ant Sa eta Case og ——_ fa ef aut te Ca, blige foo SM x @ hae Lt SL. fe knemd Wart MR | he Cr+ F Gee og Brriphaur Calbre ALA uu, otAavy, ana ZL. of F~ faz Ly BoC rete ~ x a 7 Oe a afb : ae t c . - ; ion : ° ~~ ~ + 7 * : ; < ae Aw? A: akace Pei dee of | | F ie serey se “"" RIOHMOND AND DANVILLE RAILROAD COMPANY, LAW. DEPARTMENT, ar NORTH CAROLINA DIVISION. ., OS beveserecges Pevruary 1802. : , , otovree res ewe wees tube & Delie® We to wuvtner tie’ Pieinti#r “purchases the teehet auntiouse fetm Donald's, in South Cnmslinn,te Stean’o,in Aleuander County, North Careline, paying there- fer the oun 6f $6.86,cr ust. im reply te elleg@Stion #6,Défendant aanits thet 1t 5 eeaduster set the Fiaiatif? om its trate vetween cher Wsehet, eRtStligg hin YS Pile apes the Detehdent's vend, 2 Gontco Cams 3% vendntes te semtrect of capriage «ith the Plaimtstfier thet 1¢ “wnbewfilly ane wilfully ejegt- of and rempved Vhaintiff fren ite cars.er refusse to Grrr Plaintite te his plese ef destination,” 4# wits Slean's,N.0. . K0) neering’ ts’ lhe ‘eatgnash nis after 'go,ervtmimsie Marked os $7 etch alleges thet the Plaintiff bed re- ootved infesemninn vefere he vagem his jenmnes thes his Sane tie te © eemperens cendition.and met expected al he af ar. eee ¥ " as macox so maxvi mannod COMPANY, ; Law DEPARTMENT. : NORTH CAROLINA DIVISION. mF Ss, ag Detena “sav 16 hae. a0 tnattinae ner spetinten rant ion ‘upon waton to found a belief as “e the ae ‘eotione eentatnen. 19° dese semagreets 0 : ver EDD EEDA GRE Vent or relevant evidimes in this cnse,end canset De re cotved im order to increase egy demages.te which the Pleimtift might possibly ve empitled upen the ether allegstions ef the Cemplatat. Defendent denies thet Plaistiff is emtition te recover any demages in this case. Per further defénce,this Defendanp saye thet it wae e passengers om ite read shenid shew their tiekete,er pay their fere,when called upem by the commoter,and especi- ally as applicable te the alleged fects in this ease) thet 1 wes e rule of the Derendaut Gampany thet a2) passengers om ite Lein, she sere helders of tiskete,en- titling them te trenspertetion,shgulé shew their tiekete ee ve (hes it wes the Guty of the conmoter to eject all pes cengtre whe visleted this ruls,er whe feiled to may their fures te their estimations. Defendent avers that the Piainsi¢fr was on its read fram Statesville te Tay Lorsvillewwhieh is 6 seperate sorperetion, knows ee the Statesville and Western i.k. Gempany,end thet it was the iS pe MRR rt Vee we, the A ha a NP oe ee eae we ‘ . “Law purauenint, * ¢ “ a ee NORTH CAROLINA DIVISION. ee fe he (the canmoter) would give se the Platntst? e-vesetpt fer the smme,and,if the Plaistiffe sheula fing his tieket petween Statesville and Sisen’s, that he (the cantactér) wenld returs te him the money. This the Plaistit? aise declined te.de. The cemmuster then setified the PlatstifY that he must leave the éars,and the Platatiff did lesve- net the eumurbvs ef Statesville: thet he was net fereed eft. the treih, mnt he went ogt in enedionss te the order of the cengmeter fer fatlare te pay his fare,and net ony neand was put upes him. The Defendgat denies that under tiene cireunstances, thd Pisiatif? ip eatitiod 0 reeever ennaeveereee lade Cen aisles «& cefere as this oe : ooncesencep MRR obesees ease ho coat “ee Nothihy Looe” # a 2 pa * asi eh, a Oks OLOHNOLE - x ‘. aT ae Mes AE dak © its ‘7 os eras: ’ fe. nee rary tt BLE Re tee isntase oad deta aged ° jada mort “MOO betel wetensast eas snee saettes ined ate coe | Wt TaGoaME VELIANATT O4y Ob hecegueg madd sedoube00 ott sativa" anel2 oF oliivnenast wit o1wt 03 mitt teq bine — SaeoeT e Wisstelt ede eo evts Divew (10s0unmec ods) of toxpid Sint butt bioada Y8ismiest etd %1,ban.emen odd avi. (wesoiiemte ert) ed sadd.a'meels bes eiliveesase asoused @sle Ytisaielt eds ala? . -Ceeem eds atc ef atte: binew ~ Wikdubelt ed pertis0n wea esoupmec eft eh 69 baatloed - ere bib th Wisateaty oY Bhs .etad odd Greet peste bad beete!l sea eaw ed tars toLtivessag® te errs oid deen Tebee ec? G2 someiiede at dpe snow od tus 4161) 043 re We 708 DeeeOEST Girt Coy GF GUMLIET TH) wesombasc Od? te Teen 40dt epteed teabew ted SAT wats sew Jum cer bat Te ee Ee ane aa sretssee ena, SBN cs ecce -Stabes ted wet f <6 SB rr te s! ~eelV¥ @2 "pieete ganic ianaunt tec oe “ Pit pe wrt ed ef Sa, 3 - ; Wuesiessqugtunsee es eee eevee ay eresveces veo aids OTe ee bed tx0 ada bas ef a 19"8 aan APP ete oeeooroneebesentecanes se a Wanorbsodadececsecess | e@esate or " pons pate » Paes a wee - Z 5 “IFAD Lb BaF 4 GN? ? Commission to' take Deposition. —Printed and for sale at Tae LanpMark Jos Orrwe, Statesville, N. C, Ww ORTH CAROLINA, rel In the Superior Court. ny shale of THE STATE | OF - NORTH CAROLINA TO ed x (hws ons GREETING : We reposing special trust and confidence in your integrity, do authorize and empower you to plaintiff, and .. Jefendant. And the deposition in writing, by you so taken, the same ym sealed Toe yo eat to our antag Arrcwber. [52% , Clerk of the said Court, Clerk Superior Co a) eG. erg ea oa 5 at (E54 RB Tete. get Cie pee aces PSR gee pT eS a patter Cee ye Se py je engenns ern | Jng..a,Dodson, #sq., 7. Ee i cage i a nap rg ER rr TE TIRE INIT ao SE. alg atm women gt |as having been ejected from ny train some time ago but I thine this is. } | the man that got off my train at my request because he had lost bis " > . . ° ° ~$-ead 2eiuTa gage Koco passcagers ure goicg west 27 Statesville, wrt s. = ab fare te_Shoanm this as declined to! NERS bis oe RS of a¥ 2 Statesville, WC. , Ded. 8/1891... Columbia 8.C. Dear Sir:- | ticket, this was three months ago I think, as we were leaving Sta tesyi He: I approached a passenger who ssid Be boarded the train at funtersville as I understood hiz, and that I had punched bis ticket and returned is to him and he had lost it. It is my custom to punch passengers tiokets fo ~? =, | thisbase [I did not remember this ticket and told the psessenger pe c t rotenape @iavbosige & Ot int of Statesvi I elmo tol’ : REGO y unten of Staton iyec FT eme\! Passenger to pay bis fatpe-angaf b : found bis tick&t [ would w . rg &, Poe pa e soney.. Sbetre-vas no tremble rit Ribw No words dearceiy. ane's no’ fetaey” IP ased as bhé walked off the train. Yours truly, > ‘Wm. Clarkson Condr. ASSESSES EERE RSE STRESS . . ay win = a ‘ : ¢ % 7 ‘ =, ’ : : asx nti * nw ts .< . ro ae =e. a Sees EZ ey ieee On he 27k KK Bef ALI ae eS gre oy 2 . d \- : : rT i | hall willie wu aud x deecat > amaeal (BR gte pre ee ie w," ‘ ®Q, “Ferrey othe y ‘¥ \ = c s+ ry “oe - SST te er et ee it ; A K. / HX S° Ade. Le Seg Rh Me fof ait. Ks ai : ee See All marie VA. wack pg ae jock 2c aig Sia? ates ae, of hin Gascon 402 ee ee ee ee ee c 3 4 A Medeor, GLE roa North Carolina Superior Court Iredell Comey —~ FEE rere yes sieeuieeee eee George W. Bowley mS The R. & D. R RL Co. Ww. N.C. RR. Co. The Richmond and Danville Railroad Company for Answer to the Complaint in this case says- 1 Im answer to sllegation No 1 it says It admits that the Ww. W. C. RR © is a corperation organized under the laws of North Carolina and that the BR, & BD. RR, Company is a corporation organized under the laws of the State of Virginia and is doing business in North Carolina and that it is the lessee of the Western North Carolina Railroad Company. 2 In answer to allegation No 2 this defendant says, it admits that it was a Common Carrier of passengers on the W. BR, ©. RR. op the 27th day of August 1291 and for sometime prior thereta, but it denies, thet its Co- delaniait was & Common Carrier of passengers at thet time or for sometine ew eer eTG, “wne Sard FF, SN. Ge he Obmpeny eontng lecoed [ho Sigur as mach to this defendant. 3 It admits sllegation No3 to wit that plaintiff was a passenger on its train from Statemville to Newton. --———~. —y i ST apnea e? peer = a wr 4 In reply to allegation No 4 it says It admits that its train had to pes over a viadmet about 75 or 80 feet high known as Bostian’s bridge about two wiles west of Statesville. It admits that its train was derailed aad thrown from its treck wery nett ty ant east of this viaduct and that Bintiff received personal injuries from said derailment to what extent this de@andant does not know. This defendant denies emphatically the othe allegation in this paragraph and especially the negligences therein set out. | 5 This defendant avers upon informatism and belief that some person or persona, at this time unknown to this defendant, wickedly, designedly and wrongfully took up and displaced ome of the rails of its track and thereby caused the deplorable catastrophe mentianed in Plaintiff’s complaint and the derailment of defendant’s train aad the grevious per- sonal injuries receised by the plaintiff. B.Andrewa,who being duly sworn says that Railroad Company; Personally appeared before me A. he is Second Vice-President of the Richsond & Denville That the matters stated in the foregoing Answer as of his own knowledge are true and those matters therein stated as upon information and belief he believes to be true. A771 Aor et1 1 1p | & sibeerteed before me this x. day of ABR ..tLEY Sworh to en aa Libation HH. hart hoo! nud gt a bef Aeloupiny le nn Medan. auth Leah it Lo thine Ar Chartiiliy _ TAG gon Ane __ ALE . AO ¥ POSTAL CARD @NE CENT. IN THE CIRCUIT COURT OF THE UNITED STATES Western District of North Carolina. Petition for Removal. To the Honorable, the Judges of the Circuit Court of the United States, for the Western District of North Carolina: suit entitled as above is now pending for trial and has not County, State of North Carolina; and Your petitioner respectfully shows that yet been tried in the Superior Court of [208 25-6. that your petitioner desires to remove the same into the Circuit Court of the United States, for the said District. That your petitioner is one of the defendants in said suit, and that the matter and amount in dollars, and dispute therein exceeds, exclusive of interest and costs, the sum or value of two thousan the samejis to recover damages for the alleged negligent.<t<<«- ty Aa, Blatff Make Le ae f Se - ow _4rii- operated in the said State of North Carolina, the same having a" ra to petitioner, which was wholly operating the same at the time of the apaieed RLLAG a csiieianni Your petitioner further shows that in said suit there is a controversy between a citizen seid-euieowertbrowgit. And that your petitioner and the said plaintiff are actually interested in said controversy. That said suit was brought for the purpose of recovering damages as aforesaid fr Btbiged penny L Oli tS whch oer n A te hin BEA chatg of Derg nant AF ee een ie petitioner operating as by reason of the alleged negligence of the said pet conti aforesaid the said railroad, upon which the said_.S& Cheha Me GOR onan feccnnenescnennssnnenssnnercennnves was being carried as a passenger. That, as your petitioner is informed and believes, the Western North Carolina Railroad Company, a defendant in this suit, was made a party to prevent a removal of the same to the United States Circuit Court for the said District. That, as your petitioner is informed and believes, the said Western North Carolina Railroad Com- pany is not a necessary party to the said suit, being in no way connected with the operation of the rail- road, having leased the same to the petitioner in the year 1886. That the defendant, the Western North Carolina Railroad Company, is not engaged in the business of a common carrier in the State of North Carolina, as is alleged in the complaint of the plaintiff filed in this suit. Jibei Lf f, Mamma hi. we Aney Corennn ete S toncts er mts own That this said suit was begun in the said State Court on the 5 2 3 .. hang. ox Cott S£9/ co and has not stood for trial at any term of the State Court since it was begun, as your petitioner is in- formed and believes. Your petitioner further states that he has filed herewith an affidavit that it may be made to appear to the said Circuit Court, from prejudice and local influence, your petitioner will not be able to obtain justice in said State Court, or in any other State Court to which your petitioner may, under the laws of the State of North Carolina, have the right on account of such prejudice and local influence, to remove said cause. Your petitioner therefore, prays that the said afhidavit may be accepted as good and sufficient, and that the said suit may be removed into the said Circuit Court of the United States for the said District, and further, that your petitioner be granted such orders in the premises as it is in law entitled to, to se- cure the removal prayed for ye _O o SV A_ Oa Attorney for Petitioner. Be a Fh .§ Pre . being duly sworn, do say, that I am an Attor- ney for the petitioner in the above entitled cause; that I have read the foregoing petition, and that the allegations made therein are true, except as to those made gn information and belief, and those, I be- Barge Attorney for Petitioner lieve to be true. AZ TAO . in my presence, and by AQ ew Det. IN THE CIRCUIT COURT OF THE UNITED STATES - Western District of North Carolina. : me ee eee wee see Plainhf. against rH : Affidavit for Removal of Cause. ft DOSE A Co being duly sworn do say that the Richmond and Danville Railroad Company is one of fhe defendants in the above entitled cause which is now pending for trial in the Superior Court Of Scr County, in the State of North Carolina, and that from prejudice and local influence the said defendant shall not be able to obtain justice in the said State Court, nor in any other State Court to which the said defendant may, under the laws of the said State of North Carolina, have the right, on account of such prejudice or local influence, to remove said cause: that by the accident which occurred on the railroad of this defendant on the 26th day of August, 1891, and which is the basis of this action, a number of persons, passengers and employees on the train of the said defendant were either killed or wounded, as many as twenty-two being killed, or having died from injuries received, and about twenty-seven injured, and that the said accident was at a place called Bostian Bridge, in the County of Iredell, in said State, on the date above mentioned; that the report of said accident was at once widely circulated, and many persons from the County of Iredell came to witness the scene of the accident and also many persons from the adjoining Counties to Iredell: that the dead and wounded were carried to Statesville, the County site of Iredell County, where the dead bodies were viewed by numerous citizens from the locality, and where many of f citizens of said town: that great indignation was expressed great loss of life and injuries resulting from ade upon the said defendant and the alleged the wounded were taken into the houses o by numbers of persons in the community on account of the the accident, and many harsh and unjust criticisms were m in which it had operated its said railroad: many leading citizens going so far as to dinjuries to the persons was the result of the recklessness d of human safety and human life: that a newspaper pub- County of Iredell and circulating careless manner charge publicly that the destruction of | fe an of the said defendant and its wanton disregar lished in Statesville called the Landmark, generally circulated in the also widely in the Counties and localities adjoining and around Iredell County, which said newspaper has great influence in its circulation, published articles adverse to the said defendant on account of said accident, bitterly arraying the defendant before the readers of said paper and the public on account of the said accident, whereby, and on account of which much prejudice was aroused against the said de- fendant and which still exists: that many of the persons killed or injured in the said accident were res- idents of the said County of Iredell and the adjoining Counties where their families, relatives, friends and associates reside, all of whom are, or have been active and zeal-us in denouncing and criticising the said defendant and exciting against the defendant much ill and prejudicial feeling: that other newspa- pers than the Landmark above named published and circulated in North Carolina and in the County aforesaid and the adjoining Counties have published and circulated articles bitterly denouncing the said defendant on account of the said accident, using such expressions as rotten sills, loose rails, negligent employees and other like expressions to convey to the public the impression that the said accident was due to the gross and inexcusable negligence of the said defendant that by reason of these things a strong public sentiment, prejudicial to the defendant, has been manufactured and matured so much so that this affiant verily believes that the said defendant cannot obtain justice in the State Courts aforesaid: that anumber of suits have been brought in the State Courts of North Carolina upon the alleged cause of action aforesaid, there being as many as twelve or fifteen in the County of Iredell, as many as ten in the county of Buncombe and several in other Counties, and affiant is informed and be- lieves that the parties plaintiff have made common cause in all the cases, and that they and their friends have been active in prejudicing the public mind against the said defendant with a view of placing it at a disadvantage in trials of said causes in the State Courts. ‘a ubscribed by the tll he Nisei. 7. Land awAn~my presence, and by to before me, this... Wn...day Of LA hacen. terete 1892. [FIle AUG 4 1999 =. oO. COM LES CLEp K Us. CCURT. Kuow all men by these Presents: -.. Ge i ear Bed | Morin ses, ee ee eg pi ee Se as principals, and CS a i Leecher, | - on pete se ea as surety are hereby held and firmly bound unto “s+ ex... 40 in the penal sum of Five Hundred Dollars, lawful money of the United States, for the payment of which, well and truly to be made, we bind ourselves jointly and severally firmly by these presents. : 5 cle af Cx.) Mi The condition of the above obligation is such that if... A Ft A A a District of North Carolina, on the first day of itsthen next session, a copy of the record in a certain suit now pending in the Superior Court of act of Congress, in that behalf, are required to be done upon the removal of such suit from said State Court into the said aA States Court, t Dated aaa Bs Of, eRe se wt net Leet = . STATE OF NORTH CAROLINA, / -Fat—4- County. OF anette depose and say that I am a resident of the State of North Carolina and a property-holder therein; that County, the surety name in the foregoing Bond, being duly sworn, do Lam worth the sum of Five Hundred Dollars, over and above all my debts and liabilities, and exclusive rty in the State of North Carolina liable aerated dollars. of property by law exempt from exe to execution of the value Subscribed in my presence by and by nr orn to before me this... 2 —aouday of. a ame A. D., 8&2. Pom Geel ea ns cs sc OM, B.C a BOND FOR REMOVAL TO THE U. S. CIRCUIT COURT. ‘ [FILED AUG 4 1999 2S. COAT LEwy u. S.-COURT. / D. SCHENCK, Attorney. IN THE CLROULT COURT OF THE UNITED STATES A Western District of North Carolina. : Fourth Circuit. George W.Bowley, Plaintiff. | Against Order. The Richmond and Danville Railroad Comp and the Western North Car- olina road Company. . ; Defendants. n reading the petition and affidavit filed in this cause, and upon consideration of the same, together with the bond filed and all the same being sufficient in lay, and in due form, and it having been made to appear to the Court that on account of local influence and prejudice, the petitioner will not be able to obtain justice in the State Court as set out in the petition and affidavit, nor in any other State Court, to which petitioner would have the right to remove the said cause for trial; it is considered and adjudged that the said local influence and prejudice do exist as set out in said petition and affidavit. It is further considered and adjudged that the said petition, affidavit and bond be accepted, and that the above entit] ed cause now pending in the Superior Court of Iredell County, in the State of North Carolina, be removed into the Circuit Court of the United States, for the Westerm District of North Carolina, for trial. And it is further ordered that the Clerk of this Court, at Statesville, North Carolina, do certify this order, te the said Superior Court, together with a copy ef the petition, affidavit, and bond, to the end that the said + Superior Court, may proceed no further with the cause; 2 and to the ond, futher, that the said Superior Court may | meke a full and perfect transeript of the record md | "|" proesedings had in said cause, to be tranand tted to and filed “in ‘this Court. Hugh L, Bond, aplichaslansineahieeaeenieisies nema oan ‘Unkted States of Nation, 6 hiems, ¢}. Megtern Diatriet of North Carp}ina,. A + i. H, C. Cow] ea Clerk of the Cireuit Goustt of. the. Unt tod ES States in and, fer oie District at Statesyidle,Jk Cs do j re- ~ herelly osrtity bafarexgoing to be a full, usryand perfect copy bf thé petition, affidavit, “bond and ardan-made and - * filedir se! ‘ef, chmond and Danville Railroad ae and shbprey Western orth arolina. Railroad Company. | as fully as the sme remains on file and of reoé?d inisaid ease in my offices. \, In witness whereof | hereunte subscribe my neme and affix the seal of said court, at periene in Statesville, in said District this the day of 1892. ln. bss of said Courts "SO 5 ; = ‘n _Lwoaoo * S=xrILL059 werrr.+) 6681 & O/iy ; BUDA U eh “Jj «& Vv i, baw bron zh ILSNB gerroord J Dpotlion sacloys pity gil rodeo Wye Commission to take Deposition. —Printed and for sale at Tae Lanpuarx Jos Orrice, Statesville, N. C. NORTH CAROLINA, SWELL, ons THE STATE. NORTH CAROLINA TO saeees obnevavooeonesant sacsed¥anecescoscesesese Ps wherein. plaintiff, LAL. And the deposition in writing, by you 80 taken, the same to tranamit, sealed with a seal, to our Superior Court, to be held for é Phe on the.47-.. i CUS Pein - oh LL at office audbhcrctls Clerk Superior Court. RS i [hh & Alli, ?% PHYSICIANS AND SURGEONS. nn s ai or ae Cee Nort Carolina, ) ; Superior Cou Bree. D} a bredell County. _ £ Leer ABEL 19.dmevo-! :18 to sivebriit November Term, ~~ o t - e', {Pe 4 “ e oO. Geo. W. Bowley; ' PY YeiwoT .% 1098 el ~ t "a ” vB. ‘ ! ‘ ? » The’ RichfMiond.and Danvilge feo” a em ee te ee we we me Railroad Company. and. The Western North Carolina ) ) ) ‘ ) Affidavit. ) ) ) * Railroad C . Sgr: *; o ‘is QPARY s, - ‘ a ~ \ Js Le. Scales be ing avgen according to lag, says: That he is the Aieins of the Richmond and Danville Railroad Company, at Statesville, North Carotina. That he is not the Agent of the Western North Carolina Railroad Company, and has’ not been for several viene’ “That he is not em- ployed by the Western North Carolina Railroad Company and has not been, in any capacity, for several years. Sworn to and subscribed be- ) fore me this 13th of November, ) te 1891. ) |} As SS CALLG Clerk Superior Court. Geo. W. Bowley ~ es : bt + oO c > 7 sae ee Be Oe ee ee eS Oe ee ee Affidavit of J. L. Scale. +. ‘ oe SS ey CE SC SSP EF ee SE SE Oe ee ee eee ~{ November 23th, 1891. County, North Carolina. bx balhwnb Sais Baitvonce | ag “o> Petition for Removal! of Suit to the Circuit Court of the . 2"; United States for the ........ Frezz Ro oe ky District of North Carolina. To the said Superior Court: ot (1) Your petitioner respectfully shows to this Honorable Court that the matter and amount in dis- ye pute, in the above entitled suit, exceeds, exclusive of interest and costs, the sum or value of two thou- sand dollars. 2) That the controversy in said syjt is between citizens of different States, and that the Petitioner . .@) gpatroversy in, , § i pws at the time of the commencement of this suit, and still is, a citizen of the State of « . mits: LO et heh tenet... and that ns a iE iscslincapeSerksegaae and still is, a.citizen.cliemMBtatenof 0 sancerneereentaumesscumeyenasenteenecsunees (3) Your Petitioner further shows that in said suit above mentioned there is a controversy which is wholly between citizens of different States, and which can be fully determined as between them, to- wit: a controversy between the said Petitioner, the and the said ......@................ G. $3 And your Petitioner offers herewith a bond with good and sufficient surety for his entering in said court of the United States, on the first day of its next sesdion, a copy of the record in this suit, and for pay- ing all costs that may be awarded by said Circuit Court, if said Court shal] hold that this suit was wrongfully or improperly removed thereto, and for performing any other duty required in the premises by law. And your Petitioner prays this Court to proceed no further herein, except to make the order of re- fat required by law, and to accept the surety and bond, and to cause the record herein to be re- moved into said Circuit Court of the United States in and for the uu. District of ace ot ee lw ke ese chedele terete ae ress cecscecen _ v1:«_,<o.\. and Petitioner will ever pray. Attorney Sor Petitioner =: nee STATE OF NORTH CAROLINA. Gein hog Bact hen County. ween DeINg duly sworn, do say that I am the Attorney for the Petitioner in the above entitled cause; that I have read the foregoing petition, and know the : contents thereof; and that the statements and allegations therein contained are true asQ\erily be- Cpa lieve. Subscribed by the said ee Act March 3, 1887. Oe we Oe ge Pfr ames, Seah Or Fate ee Couaty, Fac. Term, GZ KC LOPELE : Petitioner. (Act of March 3, 1887 a 0 t oad vt nani. Enc. papers in cases at Statesville ait peueed. RICHMOND OP. PARTIE Tose. COMPANY, , LAW DEPARTMENT. oh at meaner nee ca tg NORTH CAROLINA DIVISION. DAVID SCHENCK, Drvision Counsat. CHARLES PRICE, Assistant Counsel. FP. H. BUSBEBE, Assistant Counsel, GEORGE F. BASON, Assistant Counsel. D. SCHENCK, Jr, Assistant Counsel. GLENN & MANLY, Assistant Counsel. Greensboro’, NV. C., August 24th, 1892. J.H.Hill Esq., Clerk Superior Court, Baeesys+ies'-0- Dear Sir: g E o. I herewith enclose to yor, the papers in Bowley vs.the R.& D. R.R.Co.,Naomi H.Moore vs.the R.& D.R.R.Oo.,John N.Weber,admr. , vs. the R.& D.R-R.- Ope 0nd. O.W.Lawson vs.the R.& D.R.R.00- These are the papers which Mr.Bason took for the murpose of making out our appeals to the Supreme Court. I never had the papers in the case of Biggs vs.the R.& D.R.R.Co. Please acknowledge receipt of these et tt, papers . acme > I am in reeeipt of copies of the Complaints filed in the cases of Loualia Pool and f.O.U%fister vs.the R.*& D.R.R.Co. I will write Mr.Bason abont the Biggs case. Very *ymily yours, ola Division Counsel. 78 all men bu these Presents: tha we Za Ged in the penal sum of Five Hundred Dollars, lawful money of the United States, for the payment of whigh, well and truly to be made. we bind ourselves jointly and severally firmly by these presents. The condition of the above obligation is such that if _ hh. ee. = shall enter and file, or cause to be filed, in the next Circuit Court of the United States for the... itil Cn of North Carolina, on the first day of its then next session, a copy of the record in a certain suit now pending in the Superior Court of Re bib dcineddeasholiagh County, State of North Carolina, in which ee ee er SN an .w- iS Plaintiff and Lanes scsSi Sock a elachamnicipecgthaacccetnossomuamntpciccsumenuen asidaasai NRE katsSate ee Defendant and shall pay all costs that may be awarded by the said Circuit Court, if said Court shall hold that said suit was wrongfully or improperly removed thereto, and shall do such other appropriate acts as, by act of Congress, in that behalf, are required to be done upon the removal of such suit from said State Court into the said United States Court, then this obligation | to be void, otherwise of force. 18%... pf Low “Pez tome ies 772 Co -[SEAL.] STATE OF NORTH CAROLINA, Vuh County. Dated thie, day of. OE. naceseeteiie depose and say that I am a resident of the State of North Carolina and a property-holder therein; that County, the surety named in the foregoing Bond, being duly sworn, do 1 am worth the sum of Five Hundred Dollars, over and above all ny debts and liabilities, and exclusive of property by law exempt from executjog; that I have property in the State of North Carolina liable to execution of the value of ee. Sn hundred dollars sa es etna Subscribed in my presence by AAZ. £. him sworn to before me this... Az. may of ......- County, N. C. ‘BOND FOR REMOVAL TO THE U. 8. CIRCUIT COURT. HLS Hor EV PH * i, D. SCHENCK, Attorney. t | | | | North Carolina. Superior Court. Iredell County. G.W. Bowley VBe The Richmond & Danville Re Re 00s, and the Western This case was heard before his Honor Roykin,Judge, at the August term,1992,of the Superior Court of Iredell Conunty,on a motion by the Defendant,the R.& D.ReR.CO-,to sign the following order,to wit: North Carolina. Snpertor Court. Iredell County. ” G.W. Bowley VS. The Riehmond & Vanville R.R.CO. ,atid the Western . North Carolina Raks COMRADY- In this case,it appearing to the Court that the Defendant,the R.& U.R-kR.-CoO-.,has obtained an order for the re- moval of this cause into the Cironit Court of the United States for the Western District of North Carolina,all of whic appear from the petition,affidavits and bond of said Defendant, and the order of said Court dilly certified to this court,it is considered and adjudged that this Court will proceed no fur- ther in this cause,and that the Clerk of *his Court certify to said Ow Circiiit Court before the nex® term thereof a copy of the record in this case.” This motion was founded wpon the petition,affida~ of said Defendant and order of the Circnit vits and bond Court of the United States for the Western Distriot of North Carolina, certifie copies of which were filed in this Cart, and are a part of the record in this oanseé,s oertified copy of which the Clerk of this Court will send up as part of this Pl a pw sfpttthe, whe nore declined to sign the order,#nd made the following entry on the docket,to wit! "The Court de-~ ~ glines to permit the removal of this cause to the Cir- cnit Court of the United States,and declines to sign the order presented by the Defendants. "4 and from this judg- ment, the Befendant, the Ret Deke Re CO. ,appexled to the Sue preme Court of North Carolina. Notice waived. Appeal hond in tne sim of b spate qdollars adjudged suffi-e | cient. | ny C oe | wACK LEG ond ICM lap | — \\ NorTH CAROLINA, LD - COURT. ¢ 4 the Honorable .....%—<~./ MER Eb AN 8 is ro Court, to the intent that the..4-e-A-PA = — I AF And it is considered and adjudged further, that the “the cost of the appeal in Ae incurred, to-wit: the sum of Dollars (8... ey, 0 ) and let execution issue therefor. ~ A TRUE OOPY: bh baurtuia ens ‘ eo Aerie oa mM " » *. ‘*y . ; -—<—e = ee eee Fey Sao es we COS coh aed, , 7 MA Late,“ bi MAA, tnAtrie4g ee J 40t 3 che he SB Sogaa Ve, Sf? 2 LIP Coat thei. Ao Ve Mt_Aa J C1 Pere ctl) oP thw : Mtr tf f . tow thew Ol orY Litho a tc Vt ‘A, tod pow, fre scleot Ct ny, sour stale ifecren (Greet of Iredell Cai Stil) of We ag CG, oly ne pf Li, * (9S 4 wor b (Co Dy hen ghamr; Maced 4, G Lyf J- C09 AMornego z oo Is a Wp: peed Ment AOE 2h 1) eb nihy MN Be Sedtrnay (fits tf Md keorvttd I RAP Ge) Mc ptne Atak as us bddhe er Lh Eig vy ae ID es Pina. SF GF, “A LICL law GD Ore a7 OY Hho GZ yy € LOL Bunty KLM he XZ Ct) OF ding nce ye iY Fa pes f Lerche fie L) Oepodg ina if bie org OLX APOE ance Oat Cues Le PO’ Ad> C72 (fAicote KG PV Sew aberdentitled Ze evry tLe ec ser ] FlLOtO-Y rh, a4 reg tr ee Liges j«d->~ yet A-of, An aki or aleg bACE g Fhe (Onrorbrr wy a Sora D arc BrvO Yartfifec “ry 4, rt klBa one a Ce Y S SY 4? pa 53 T. J. ALLI. LISON, Sheriff, Iredell Co, s * * Commission to take _Deposition— Printed and for sale at Tae LanDMaRk Jos Orrws, Statesville, N. C. NORTH 7 OLINA In the Superior Court. i cones 4) — THE STATE OF NORTH CAROLINA TO ot th ebund GREETING: eS special trust and confidence in your integrity, do authorize and empower you to Mead, oll O Manta oa and.. dtcaied oath to examine touching all such matters and things as..... <<7.% to appear before you at such time and place as you may appoint, shall know of and concerning a certain matter of controversy in our Superior Court for the county Ot oan Ith dhl... panne tacbins pending, woorein.. ee. al Cheteotededne FCO. suenenegs ALLY... plaintifffand.¢ he Ane bemandétQnarvunthe eradraad kee — in: Serle defendant. And the deposition in writing, by you so taken, the same to transmit, sealed with your seal, to our of, Pi crember. SEG St VE. Z ol be anatK RRAD : - SA eainclOnh% AAD ot b-ina Lidloma, PPG es SPL’ -_— of fling Ad ge | HG ie nd, | a fs FE. pAon 92 Leorzeig SI Mac tor, ate WL) Far Hi be 2€c Ff yarn FO Aaniifife y Lat fea JL 6 tari/ i ae oe at area ye Ay. °C Let Ch Some og Mirch, Convo og e020 x) PE FY Ppcticense Aa tl ~oé a ~ . ee Sheriff , Iredell Co, * * The depositions of J. 0. Martin and Geome D. Thaxton taken be- fore Sol. Cutehing, a commissioner duly authorised and empowered by the Superior Court of Iredell county, State of North Carolina, to cause the said George D. Thaxton and J. 0. Martin te appear before him at such time and placé as he may appoint, and upon their oaths to examine touching all such matters and things as they shall know of and concerning a certain matter of controversy in the said Superior Court for the said county pending, wherein George D. Thaxton & Co. are plaintiffs and the Richmond & Danville Railroad Company is defen- dant, ( a copy of which said commission is herete attached, bearing date on the Slst. day of August, 1608,), pursuant to notice hereto annexed, on this, the 2lst. day of September, 1808, at the office of Sol. Cutchins, in the city of Richnond, Virginia. B. B. Munford, Eeqr., Counsel for the Richmond & Danville Railroad Co. No counsel for the plaintiffs. J. 0. Martin, a witness of lawful age, being first duly sworn, depo- ses and says, in answer to written imterregatories propounded by Frank D. Hackett, Esqr., as follows: lst. Question: State the mames of the individuals composing the firm of George D. Thazton & Co.? Answer: They are myself and George D. Thaxton. 2nd. Question: State their place of business and the kind of business in which engaged? Answer: Their place of business is No. 14 South lath. Street, in the city of Richmond, Vinginia, ari they are engaged in the wholesale Netions and Dey Goods business. 3rd. Question: State the class of trade with ghich you deal and the sections i 8 “os Me | Some * 4 e , r < ‘ . : 1 ‘ , ed ‘ * gard oe Sc nel lai ce ~~ — oe ~~ _- we A wa —— Satz cialbed wives va mabe’ wriin va nits FROM R GooDs.-@a ae — D. THAXTON, Ss: J. ©, MARTIN. Richmond, Va., — oe = Woorens, | Keene JEANS, TRGINIA £ renee gam pea peal froons, ee eae aa GEO. D. THAXTON & (0.2 emg Meticaitd TIONS, WHITE GOODS AND PIECE GOODS, ee. ae ijuhiaC dae Oak oie Wo. 14 8. FOURTHAENTH St. NY | IN G NY AIS = L Zo | | i . a £2 10a cla<cen a I (Gene: SS ee Oe ee ee [a3 Se a) oe Sense eee seems ws eer oe bo sued Ain ak oe wore defeated where located and how reached by you? Answer: We sell prinéipally te country merchants in Virginia and in North and South Carolina, in West Virginia and the northern part éf Georgia. ‘Those sections are reached by the different lines of wail- road leading from Richmond, and we ship a great many goeds by the | | Riehmond & Danville Railroad. 4th. Question: : State whether you shipped any goods in the month of August, 1891, to a party neer Statesville, 4H. C.? : Answer: We did. Sth. Question: State who that party was, what you sold him, and if at the reg- ular market prices? and on what terms? Answer: J. Re Norman. We sold him a bill of notions, a copy of which, showing the items and the prices charged for the same, I herewith file, marked Exhibit J. 0, M. Mo. 1, the terms of the sale were 7 4 eff for cash and the prices at whieh they were sold were our regular prices, and as low as the goods could be sold. Oth. Question: How were the goods shipped? Answer: They were shipped by the Richuen® & Danville Railroad. Tth. Question: Have you been paid for these goods? Answer? We have not. Sth. Question: State if you ever gued J. Ki Norman for the value ef the goods sold him, and state the result of the suit? Answer: We sued him and we were defeated. 9th. Question: De you knew on what grounds Noman based hie defense? Answer: We were informed that he based it on the grounds that he had never received the goods. Norman made that statement to us long be- fore we sued him for them. 10th. Question: Did you ever make claim against the Richmond & Danville Railroad Company: for the goods on account of their failure to deliver te Norm Answer: : After having the trouble with Norman we put in a claim against . the Richmend & Danville Railroad Company. llth. Question: | Did they pay your claim? Answer: They did not. And further this depenent saith not. Sp J Jp fda George D. Thaxton, another witness of lawful age, being first duly sworn, deposes and says as follows, in answer to the written in- terrogatories filed by Hackett, Beqr. lst Question: Sate the names of the individuals composing the firm of George D. Thamten & Co.? pi Answer. | They are myself, George D, Thaxton, and J. 0. Martin, the plain- tiffs in this suit. Gnd. Question: State their place of business and the kind of business in which they are engaged? Answer? Their plescof business is No. 14 South l4th. Street, Richmond, Virginia, and they are engaged in the Wholesale Dry Goods and Notions trade. Srd. Question: State the class of trade with which you deal, and the sections where your trade is lecated, and how reached by you? Answer: We deal with country merchants, principally, in the states of Visginia, Newth Carolina, South Carolima, Geomgig, Termmesee and Vest Vigginia, and they are reashed by railread, chiefly. 4th. Question: State whether you shipped any goods in the month of August, 1891, to a party near Statesville, N. C. ? Answer: We did. : Sthe State whe the party was, what you selé him, on what terms ard if at the regular market prices? Answer: The party was J. R. Norman, we sold him @ bill of notions, « copy of which is filed with the deposition given by Mr. Martin. The terms of the sale were 7 % off for cash, and the prices at which they were sold were our regular prices and as low as the goods could be sold. 6th. Question: How were the goods & shipped? Angee They were shipped by the Richmond & Danville Railroad. Tth. Question: Have you been paid for these goods? Answer: We have net. 8th. Question: State if you ever sued J. R. Norman for the value ef the goods sold him, and state the result of the suit? Answer: We sued him and we were defeated. Sth. Question: Do you know on what grounds Norman based his defense? Answer: | He informed us that he had never seoeived the goeds, and we un- derstand that is the reason that we failed te get judgment against hia. 10th. Question: Did you ever make claim on the Richmond & Danville Railroad Conm- pany for the goods on account of their failure toe deliver to Norman? Answer: We did and we tried to settle the mtter without suit. llth. Question: Didthe,pay your claim? Answer: They 414 not, and for that reason we browht this euit to o- foree the payment of it. And further this deponent esith not. EUR ALG, I, Sol. Cutehing, do certify that the forageing depositions of J. 0. Martin and Geonge D. Thazten ware duly taken, sworn to and sub- scribed before me at the time and place indicated in the notice herete qemened, by virtue of the authority vested in me by the com mission issued from the Superior Court for the county of Iredell, in the state of North Carolina on the 3lst. day of August, 1892, and hereto attached. Given under my hand and seal at Richmond, in the state of Vir- ginia, this 2lst. day of September, oe Fee $2.00. 4 Py yas plaintiffs. Hit the; bf) Cz 2 S 2h, p ( ‘ SLAG se Gn wh L y. een a fe i PT aS oueur-or GEO. D. THAXTON & 00, Paver peyn IMPORTERS AND JOBBERS OF ae gee Aawitl, “NOTIONS WHITE GOODS AND PIECE GOODS, All Bills must be Settled in 30 Days, eltier-by Cash or Note. WoO. 14 Ss. FOURTHENTH ST. © Sasa. a Gabe ak | 1. 100 : | O21 Ho hfs , | 137 7 SB LE- ; | Go “ot, 1 Spon Pact Chee’ 43 <a | SSL Vor fe SISG Yr _, ae / alee! PLIES en oes Ft | cl nm CP eran Dye ry: | a 17 | heel! ta KO” | _@ee \/| Rhy ® 4 x Scat AA fMa | Ln Duvet, BAKaunks At Vor h CHU 2 ol. ae » so | Vo | et CU as Aura ts L3T_ | A were Pert Seu Qt XSF 2 Ky g- 73/e Obtiter 13 FE ) =. ~ =! ey Ve 4 ; Ao hate tsa / 4 G fe: FOR INFORMATION, &c., APPLY TO t, 228 Wi Street, Boston. G. F. NexpHam, G. F. A., York River Line, Baltimore. er. & Miners Co., Providence. C. M. Borum, D. F. A. Virginia Midland Div., Lynchburg, Va. ; Agent, No. 88 South 5th Street, Philadelphia. J.8. Ports, D F. A. Richmond & Danville Div.. Richmond, Va. F. M. IRONMONGER,: nt, 229 Broadway, New York. W. A. Turk, D. F. A. North Carolina Division, Raleigh, N. C. W. L. GurnuaupDEv, G, F. aa 197 Greenwich St., New York. L. L. McCumsxey. D. F. A., A. & C. Div., Atlanta, Ga. DPD. D. C. Mryx, G. FA. Clyde Line, Philadelphia. D. CARDWELL, D. F.A.,C. & G. and 8 C. Divs., Columbia, 8. C. @ro. R NEEDHAM, Agent. 233 E. German Street, Baltimore. W. A. WiINBURN, D. F. A., W. N. C. Div., Asheville, N. C. | J. H. Drake. General Freight Agent Richmond and Danville Railroad Company, Richmond, Va. on Shipments to and from West Point proper, and to and from Eastern Cities through Wess Polts or Damage and all other ts the and Danville Railroad, incl Shi ts . ai sn Dastilie’ Dezratek, Should bosens ts 5:15: DRAKE, General Freight Agent, Kiemmend. Va. Dhrough Bill of Leading. (j . Value of Packages Unknown. | GNo liability will be a» | Received of A gt sumed for wrong carriage in outward apparent good order, inward dition of contents) this Company or any of qpendible gg Phgs. | by the Richmond & Danville Railroad Company to," ‘ ‘ thence by connectifig lines to A and any and all marine risks. from any « TY) worl ighyl-~ margin, t be transported as above specified, and dottvered to the or steamer, sad ju like manner i : H FE i i ! all. of its this Bill of Lading 3 y : iy rH H | : | i § | | i i ic ef | f i i gf | 7 i it if it § ie lh : i) i fl EBe + Lf e Xs * Commission to take Deposition.—Printed and for sale at Tae LanpMark Jos Orrice, Statesville, N. C. NORTH CAROLINA, cote COUN @Y. In the Superior Court. “THE STATE OF NORTH CAROLINA TO 2¢- AO ucteehuna ic: We ke, Henn special trust and eas your integrity,do authorize and empower you to — ca ure... Clerk Superior Court. LCA | P (Oo . sy io Velev 5 hl am wate, 2 ks ae gy met feet ‘ sda cect tat eons 7 pate omaniaperr i wr Baey¥ Ge Vhs Ames es hab GBedrriuye foleatelen ddl J» Office of Sol. Cutchins, No. 1002 East Main Street, Richmond, Va., July 28th., 1892. Met pursuant to adjournment. Present J. 0. Martin, of the firm of George D. Thaxton & Co. J. 0. Martin, a witness of lawful age, being first duly sworn, deposes and says as follows, in answer to written interrogato- ries submitted by Frank D. Hackett, Esqr., counsel for the plain- tiffs. | / -. ste Question. State the names of the members composing the firm of George D. Thaxton & Co.? Ans. George D. Thaxton and J. 0. Martin. 2nd. Question. State their place of business and the kind of business in which engaged? Ans. No. 14 South Fourteenth Street, in the city of Richmond, Virginia; and they are engaged in the Wholesale Dry Goods and Notions business. Srd. Question. State the class of trade you deal with, and the sections where that trade is located, and how reached by you? Ans. We deal with country merchants principally, located in the states.of Virginia, North Carolina and South Carolina. Those sections are reached by different lines of railroad rumming out from Richmond. We ship a great many goods by the Richmond & Danville Railroad. 4th. Question. State whether or not in the month of August, 1891, you shipped any goods to a party in western North Carolina, near Statesville? Ans. We did. 5th. Question. State who that party was, what you sold him, on what terms sold, and if sold at regular market prices? em OR The deposition of J. 0. Martin taken before Sol. Cutchins, at his Law Office in the city of Richmond, Virginia, by virtue of the authority vested in him by a commission issued by the Su- peripr Court for the county of Iredell, in the State of North Carolina, bearing date on the llth. day of July, 1892, and here- to attached, and pursuant to notice, a copy of which is hereto attached, to be read as evidence on behalf of George D. Thaxton & Co. in a certain action pending in the Superior Court for the county of Iredell, state of North Carolina,’ in which the said George D. Thaxton & Co. are the plaintiffs, and the Richmond & Danville Railroad Company is the defendant. Law Office of Sol. Cutchins, 1002 East Main Street, Richmond, Virginia, the 27th. day of July, 1892. Present;J. 0. Martin, of the firm of George D. Thaxton & Co. On account of the indisposition of the Commissioner the taking of these depositions is postponed and continued until tom morrow at the same place and between the same hours, that is to say between the hours of 9 A. M. an Commissioner. ae S@F ALL CLAIMS MUST BE MADE WITHIN TEN DAYS FROM RECEIPT OF GOODS.“@A tit Dn 2n35, 0. wantin Sat Richmond, eS. 252.189 | TRGINIA if a TROIMIA oo Me 2th tbr peal oo ea Dt mons = RowGHT OF GEO. D. THAXTON & C0., Pxverwear, IMPORTERS AND JOBBERS OF Seppe’ 0 BLE LEN TIONS, WHITE GOODS AND PIECE GOODS, ao - a Ss ee either by Cash or Mote. NO.7. 14 8S. FOURTHENTH Sst. Ans. The party was J. R. Norman, of Osbornville, N. C., ship- ping point StatesviYle, N. C. We sold him a bill of notions, a duplicate invoice of which I herewith file marked Je O. M. No.1, to be taken as part of my answer to this question. The value of the goods sold and shipped to him on the 25th. day of August, 1891, is $64.05; the terms of the sale was 7 % off for aux cash, and on the same day that the goods were shipped we drew on him for the amount of the bill less the discount of 7 %. The goods were sold at regular market prices and as low as we could afford to sell them. 6th. Question How were the goods shipped ? Ans. They were shipped by the Richmond & Danville Railroad to Statesville, N. €., and they were marked J. R. Norman, States- ville, N. C. Tth. Question. State if party has paid for the goods; and if he has not paid for them give the reasons assigned by him to you for non-payment? Ans. He has not paid for them, and the reason assigned by him is that he has never received them. He says that he sent to the depot of the Richmond & Danville Railroad Company for them on several occasions but that they were never delivered to him, 8th. Question. State whether you sued the party for the value of the goods, and what defense party made, and whether you obtained judgment syain aginst him or not? Ans. We sued him for the value of the goods, and he claimed that they had never been delivered, and for that reason we lost our suit and failed to obtain a judgment. At this point Beverly B. Munferd, Esqr., counsel for the Richmond & Danville Railroad Company,appeared and filed the fol- lowing exceptions, ‘to wit: The Richmond & Danville Railroad Company by counsel accepta to the 7th. Question and the answer thereto as being illegal. The statements detailed by the witness being conversations or repre- sentations made to him by some on else. And for the same reasons 8th. Question and the answer thereto ax are excepted to. 9th Question. State if you have had any correspondence with the Railroad Com- pany( The Richmond & Danville) in regard to the goods in ques- tion, and give as nearly as you can the substance of that corre- spondence; and then state what action you have taken and the re- sult of said correspondence? Ans. The only correspondence that we have had was to put in a Claim for the goods, and all the papers are in the possession of the. Railroad Company’. They refussed to-pay the clain. And further this deponent saith not. LOM aad. State of Virginia, City of Richmond, to wit: I, Sol. Cutchins, a commissioner of the Superior Court for the county of Iredell, in the state of North Carolina, authorized and empowered to cause George D. Thaxton and J. 0. Martin to come before me and to examine them on oath touching all such matters and things as they should know of and concerning a cer- tain matter of controversy in the Superior court for the county of Iredell pending wherein George D. Thaxton & Co. are plain- tiffs and the Richmond & Danville Railroad Company are defen- dants, by a commission issued by the said Superior court for the county of Iredell on the llth. day of July, 1892, do certify that the foregoing deposition was duly taken, sworn to and sub- scribed before me at the time and place therein stated. - Given under my hand and seal this 28th. day of July, A. D., 1892. : if 7 Ko Face huprri Bir: funy 12-1072 1th Gosrtim e Pi gheniae Cut - tuceeee Ca, ~“ Kivi, LESe. = ET. 2 eats: — grew h fra. ines J ax “hei, otros tie Pasian. > _ Off one ~ ce Ug oh Mas oe te | | | | Bae © Gout fica» ) ee LaZD ) fue tor oe | ec ALEEE poke ll /, Boba): fo ut7 Oe nw ane He ee te) ad C7 ec. oa aig et Gee Lai dave APLLAE’ CCL Ba AME Zee ) fa gs ge slice Lo t60) Lact om Wy & ate — Y oH a ee LEPC a V2 p00 Altova AAZAZ ae 7te ZALtA><e ial fig-ea , ( LE aus pu Gant \Leacececw te etal piles CLL” KD - Dre (ite wer fer ene Gp, 5b Qe es Bed 4 SF LL BiativiD. Linea ALC. Sa Zee ) Yt ©“ C2 = Lis te ey Me fia Ciifcwe OEP 0) LE actif fp Z breefel a oy ae tllec PLE Say y age LLL Lois \ Jseecvittid, Fiz lint alba, ‘Bw SY ox Fz oy Witter s age A. 2 Ze|) V/ tt Cuffs (poe bt ib Seki beeen Z ym ie we) Lt (La pea acai gee ae alee ee Lies: ra GobL Ma eae Finnmion 2 A: Ltn LAO. : LE 1S 27 Lteere | a Ze SS 22 fuvect> aa oe is acta teai2thH \/piaar Zeca ra Z sed AI Is ease BZ Geof oe Cr i Lon gem acme: Sat el le | Z rzt{) | ae rs Ben Berea at 7 ao poe / 42> ZLC A a oe ye Li ii Z0e 2ocH off : eh 4 beat “ace ZO. lc wns lett | Is VE ( LAP C001 AY Abin Valea) 4 fl LAttiad /Jlg ys Wat, J Ok Yd} Wéle hiarkc She 4 Lf ah. ZS 0 are Pal vs Be yt bl teiléd ttle?) re Z o 4 LZLLCS. OZ 4 i 227 fae: age tens aa. HL. he + Baz ee YO Wale hor Crt VG - ble a ~. brs a donntna Killa | ensens BOL 9 Rell. Connie. iceiigeia Pommaiomigieapare= ontop fo ti oot mato fi hey be, wR reslored « rune 4 R Wirkhrn Hirth Borel i ) Cait fork soit SEX of fv Ol Coecne | a eae by heparan ou He FmifbrTin @ he Ret Lee& Cn dpid Pelroet 27 2 Faperet At (ar ge ON Lae: 6 pe eer per eae ae ee Ces. mere ic poms re Aaa ge An etm. ont 68 epee odie Fetal Fok toed of forafer rfes vant tae Orelje, ant Me Af clit tanrA wraefe trl te Om fo eee te wot i, fom He Ft wt moet tp ee au. Atay ts i a brApe at twtrotbApraX% Zo * fort Mirlane GM 6 oh os 7 a Large Ombarion at firth, Ax auAt_al actA Se tat Feta es bornCr ee Gre Had S12 6, torte Oe Ceawdret wh Rita botm : . oe - Lave: 4.2 bmta 9 drt Frauke Crores ff Pani, wiry ofpfert. RICHMOND AND DANVILLE RAILROAD COMPANY, LAW DEPARTMENT. 2K om Oe NORTH CAROLINA DIVISION. S@eeceeveeootseeoee Fevruery term, 1802. VSe ‘The R.& D.R.R& The - | |W.N.O.R.R.Companies.:- AMBWER: @eccevoaseonesebsé The Defendants, answering the Complaint im this case,sey: — That they a@mit ellegatien #1. Im answer to ¢@,the Defendants sey that the Ref D.R.RsCe is the lessee of the Wsi.0.R.R.0e. end tas operating the seid reed on thé 97th Giy Of Anguet,1001,0nd sines that time, and at the time of the Gecident complained ef. In reply te allegation 46, the Defendant s admit that the Plaintiff was a passenger fer hire on ites cars,and that she had a regiler tieket from Selisvury to Paint Reck. In reply te allegation #4, the Defendants admit that its eats had te pess evér 6 vie@iet, known as Bestian’s Bridge, situbtel twe miles Hest of Stétesvilie,60 er 70 feet high: They e@mit thet their train was wrecked et thet peint on the s7th Gay of august, 1901. The Defendants deny thet they"wilfilly end neg- ligemtly cemsed,er permitted sefd vridage er ite super~ structure er the appreaehes therete er the track leading to and from said wrtdgé;te U6 ruinous, dilapidated, retten unsafe,end impreperly censfrusted." They deny that they “wilfelly end negligently permitted the cars ef said treia,upen which she and her veggage were being treme~ pe@iod, te ve in a defective amd unsafe condition". Thay was being transported, "with great opeed and recklesenees and witheut Gre carp end eatition.” They deny that there _ RICHMOND AND DANVILLE RAILROAD COMPANY, LAW DEPARTMENT. NORTH CAROLINA DIVISION. was any defective construction eof the said vriage er the quperatiustibe,er of the appreaches to ane fiwe sid | ereige and the tract theresn,ana eestig<igus te sate wridges" or that they allowed it to rempin in @ rotten and unsafe condition,er fey want of proper repairs, er that the vailreed track er reed bed was defective ané un safe, and defendants Geny ench and every charge Of negli~ gemee made against them in the said Oemplaint. fhe Defendants admit that Plaintiff wae tajused by peason ef the seid ereck,ut they deny thet she was im jured through their negligence. The Defendants deny that the Pleintiff was injured te the exten§ ef ten theusend @ellers. The Defendenty have ne knowledge ner sufficient information pen which to form a velief es te whether Plaintiff is permeséntly injured er net,er es te the extent ef her injuries,but Defendents are willing te ad- wit thet she wae sertensiy injured. The Defendants éeny,wpen information and veliof, that the Pletetiff hed te pap three mmndred épllere fer beard and @edienl service at Statesville. lm vregaré te the eampe of the esticn fer o mundred ané maneteen dellers fer the less ef o tram and its ese- tents, the Defendants deur therete for want ef jurisdic tiem im this Ceurt,ené sag@ this Court kes ne sight jeriediotion ef that eum fer & preach of contract in the Ucn pew Lets of Yims tT 6 caggege Ogunse] fer Defendant. RICHMOND AND DANVILLE RAILROAD COMPANY, LAW DEPARTMENT, NORTH CAROLINA DIVISION, “Qn. Bricky cs, +See , Deine peing @uly swern,says that he. is op ® Dekville Railroad Osmpany , te efficer me see he macieae © Me eam wit: thas a is ¥ akan That the pine eteted in this aAnswer,ef his @& own knowledge are truc,and these stated on iaformat ion he velioves te be true see pre iS secret shewhendenvei ii dihere f CA Svern te and Smee or | ie oe TR ee 550i sas aay of A aimee ( sete 7 hho? ... Mat Od -$add aqen.atene ‘Ulm gated, awethwa.d.a of, quequed Maweiten wLiivded ‘4 beemioti edt 10 wolrte —— Saehiee1T-OBlV et ec sade :3itw |, { Otd: Teywewems: O29 ui besese or0ssam edd seit meltewsetat me betets ceeds bas.0id 018 epbelvent ave @irtd Od OF sevelled ef . SOCPSC Oe Te Cede eHede Teds eeseocces cocecccse-e S£AS GH Greted bedii10edm has ef atewe OTE ceccccessweccccccececs eocvcscooee TO tab SUCCESS CSEES CEH SE CEH SSESeS ese IN THE CIRCUIT COURT OF THE UNITED STATES Western District of North Carolina. PM t712/ I tA A MO eee ee eee ee ee ee ibdiatt sien dello Siisbale chet hae Rivka wsooeb| elves melas tcvimancuy hertioy ed pias aif a Petition for Removal. To the Honorable, the Judges of the Circuit Court of the United States, for the Western District of North Carolina: ove is now pending for trial and has not County, State of North Carolina; and Your petitioner respectfully shows uit entitled as yet been tried in the Superior Court of WAc"=t= that your petitioner desires to remove the same into the Circuit Court of the United States, for the said That your petitioner is one of the defendants in said suit, and that the matter and amount in District. dispute therein exceeds, exclusive of interest and costs, the sum or value of two thousand, dollars, and the same is to recover damages for the alleged Sk» Gadcnpen Mawnrk ezese A _) en leased to petitioner, which was wholly operated in the said State of North Carolina, the same having be operating the same at the time of the oeretnr Your petitioner further shows that in said suit i is a controversy between a citizen i < chee Cae saan me seid-oute-warproupm. And that your petitioner and the said plaintiff are actually interested in said controversy. by reason of the alleged negligence of the said petit) aforesaid the said railroad, upon which the said was being carried as a passenger. That, as your petitioner is informed and believes, the Western North Carolina Railroad Company, a defendant in this suit, was made a party to prevent a removal of the same to the United States Circuit Court for the said District. That, as your petitioner is informed and believes, the said Western North Carolina Railroad Com- pany is not a necessary party to the said suit, being in no way connected with the operation of the rail- road, having leased the same to the petitioner in the year 1886. That the defendant, the Western North Carolina Railroad Company, is not engaged in the business of a common carrier in the State of North Carolina, as is nae in the complaint of the. plaintiff filed in this suit. Bek A ta i eee ia ee ew wae Pe rate this said suit was begun in the said State Court on the..." 7... ON .. ee a2 ass ssanlgngusissitierSinsapclanaup puahgeRiatiod and has not stood for trial at any term of the State Court since it was begun, as your petitioner is in- formed and believes. Your petitioner further states that he has filed herewith an affidavit that it may be made to appear to the said Circuit Court, from prejudice and local influence, your petitioner will not be able to obtain justice in said State Court, or in any other State Court to which your petitioner may, under the laws of the State of North Carolina, have the right on account of such prejudice and local influence, to remove said cause. Your petitioner therefore, prays that the said affidavit may be accepted as good and sufficient, and that the said suit may be removed into the said Circuit Court of the United States for the said District, and further, that your petitioner be granted such orders in ty@ premises as itis in law entitled to, to se- cure the removal prayed for Attorney for Petitioner. oes . being duly sworn, do say, that I am an Attor- ney for the petitioner in the above entitled cause; that | have read the foregoing petition, and that the n information and belief, and those, I be- Pi Acai allegations made therein are true, except as to those m lieve to be true. Subscribed by the said hh. hi fore me, this oa bedi day oh secik = Attorney for Petitioner. . in my presence, and by = f “y e ~~ EFILED ; AUG 4 1999 & & cowie CLERK U.S.cOoURT. ” 7 a IN THE CIRCUIT COURT OF THE UNITED STATES ae ‘Western District of North Casolina. O4ns AL. 7 Cree SIERRA ' ees ie nas : _ e , REY eae aa wer Plaintiff. Me I fe Affidavit for Removal of Cause. the above entitled County, in the e defendants i that the Richmond and Danville Railroad Company is one of cause which is now pending for trial in the Superior Court of 00> State of North Carolina, and that from prejudice and local influence the said defendant shall not be able to obtain justice in the said State Court, nor in any other State Court to which the said defendant may, under the laws of the said State of North Carolina, have the right, on account of such prejudice or local influence, to remove said cause: that by the accident which occurred on the railroad of this defendant on the 26th day of August, 1891, and which is the basis of this action, a number of persons, passengers and employees on the train of the said defendant were either killed or wounded, as many as twenty-two being killed, or having died from injuries received, and about twenty-seven injured, and that the said accident was at a place called Bostian Bridge, in the County of Iredell, in said State, on the date above mentioned; that the report of said accident was at once widely circulated, and many persons from the County of Iredell came to witness the scene of the accident and also many persons from the adjoining Counties to Iredell: that the dead and wounded were carried to Statesville, the County site of Iredell County, where the dead bodies were viewed by numerous citizens from the locality, and where many of the wounded were taken into the houses of citizens of said town: that great indignation was expressed by numbers of persons in the community on account of the great loss of life and injuries resulting from the accident, and many harsh and unjust criticisms were made upon the said defendant and the alleged careless manner in which it had operated its said railroad: many leading citizens going so far as to charge publicly that the destruction of l:fe and injuries to the persons was the result of the recklessness of the said defendant and its wanton disregard of human safety and human life: that a newspaper pub- lished in Statesville called the Landmark, generally circulated in the County of Iredell and circulating also widely in the Counties and localities adjoining and around Iredell County, which said newspaper circulation, published articles adverse to the said defendant on account of said has great influence in its ers of said paper and the public on account of accident, bitterly arraying the defendant before the read the said accident, whereby, and on account of which much prejudice was aroused against the said de- fendant and which still exists: that many of the persons killed or injured in the said accident were res- idents of the said County of Iredell and the adjoining Counties where their families, relatives, friends and associates reside, all of whom are, or have been active and zealus in denouncing and criticising the said defendant and exciting against the defendant much ill and prejudicial feeling: that other newspa- pers than the Landmark above named published and circulated in North Carolina and in the County aforesaid and the adjoining Counties have published and circulated articles bitterly denouncing the said defendant on account of the said accident, using such expressions as rotten sills, loose rails, negligent employees and other like expressions to convey to the public the impression that the said accident was due to the ‘gross and inexcusable negligence of the said defendant that by reason of these things a strong public sentiment, prejudicial to the defendant, has been manufactured and matured so much so that this affiant verily believes that the said defendant cannot obtain justice in the State Courts aforesaid: that anumber of suits have been brought in the State Courts of North Carolina upon the said, there being as many as twelve or fifteen in the County of Iredell, as many as ten in the county of Buncombe and several in other Counties, and affiant is informed and be- lieves that the parties plaintiff have made common cause in all the cases, and that they and their friends d against the said defendant with a view of placing it at have been active in prejudicing the public min a disadvantage in trials of said causes in the State Se Aw ee A. PR Te Ae presence, and by alleged cause of action afore ' CLEMK U.S. COURT. now all in t Presents: ia vA jd Pe Ku bate Pp te a as principals, and as surety are hereby held and firmly bound unto ¢ in the penal sum of Five Hundred Dollars, lawful money of the United States, for the payment of which, well and truly to be made, we bind ourselves jointly and eenweny firmly by these eee , or Cause to be filed, in the next Circuit Court of the United States for the....._. Ce. District of North Carolina, on the first — then next session, a copy of the record in a certain suit now pending in the Superior Court of and shall pay all costs that may be awarded by the said Circuit Court, if saif’Courfshall hold that said suit was wrongfully or improperly removed thereto, and shall do such other appropriate acts as, by act of Congress, in that behalf, are required to be done upon the removal of such suit from said State Court into the said ae Court, tWen this obligation to be void, otherwise of force. Dated this... day of OLINA, County. . County, the surety named in the foregoing Bond, being duly sworn, do depose and say that I am a resident of the State of North Carolina and a property-holder therein; that I am worth the sum of Five Hundred Dollars, over and abov of property by law wT Eee c to execution of the value o ll my debts and liabilities, and exclusive € property in the State of North Carolina liable etemeetth <—) _y-aertred dollars Subscribed in my presence b him sworn to before me this... ~ ...day of. eh SNe panties ss liaedllial ne vs. petatbigrip tite eek s oles nd sack LOONEY, B.C. BOND FOR REMOVAL TO THE U. S. CIRCUIT COURT. AUG 4 1998 : * CLERK U.S.COURT. ” D. SCHENCK, : Attorney. AN THR CEROULT OOURT OB THE UNITRD STATRS Western District of North Carélina. e * Plaintiff. the Richmond orid Danvi}}e Rail road Compiriy “anit Wie Western North Oars" olink Raf? ron Company. Defendenits. | | : Upon reading the petition and ef fidavit filed in this omnes and upon consideration of the same, together with the bond filed and all the same being snfficient in lam, and in dud form, and it having been made to appear to the Court on account of loeal influence and prejudios, the petitioner will not be able to obtain justice in the Sthte | Oourt as set Out In Me petition ana affidavit, nor in any | other State Court, to which petitioner would have the right t romove the said cause for trial; it is considered and adjudged that the said Joao] influence and prejudice d exist as set out in said petition amd affidavit. It is further considered and adjudged that the said petition, affidavit and bond be accepted, and that the above entitled cause now pending in the Superior Court of Iredal} County, in the State of North Carolina, be removed into the Cireuit Court of the United States, for the Westem District of North Carolina, for trial. * And it is farther ordered, that the Clerk of this Court, at Statesville, North Carol ina, do certify this order, to the said Superior Court, together with a copy of the petition, affidavit, and bond, to the end that the said Superior Court may proceed no further with the cause; and to the end, furthé, that the said Superior Court may make a full and perfect | transcript of the record and proceedings had in said case, | to he transai tted to and filed in this court. Hugh L. Bond, Cr. Judge. | United States of America. | Western District of North Carolina. I,.H.C.Cowles Clerk of the Cirouit Court of the United States in and for said District at Statesville,N.0., do hereby certify the foregoing to be a full, true and perfect copy of the petition, affidavit, bond and order made and filed in the case of, @==huuumm, Narr Mo D7) O-er- 2. against the Richmond and Danville Railroad Company and the Western North Carolina Railroaf Company as fully as the same remain on file and of record in said cause in my office. In witness whereof I hereunto subseribe my neme and affix the seal of said Court, at office, in Stat lle, in said District e © “day of Agust 1892. Clerk of said Court. ',@ North Carolina. Superior Court. Iredell County. Naomi H. Moore va. The Richmond & Danville R.R.G0.,and the Western North Carolina vse Colpanye | "peocvse Case on Appeal. This case was heard before his Honor Boykin, Judge, at the Angust term,1892,o0f the Superior Court of Iredell County,on a motion by Defendant,the R.e&« D.R.R.Ce.,to sign the following order,to wit: "North Carolina, Supertor Court. Iredell County. Naomi H.Moore vs, The Richmond & Danville R.R. Co.,and the Western North Carolina R.R.company- In this gase,i* appearing to the Court that the Defandant,the R.* D.R.R.Co.,has obtained an order for the removal of this canse into the Cironit Court of the United States for the Western District of North Caroitina all of which appears from the petition,affidavits and bond of said Defendant and the order of said Court duly certified to this Court,it is considered and adjudged thet this Court. #ill proceed no further in this onse, and that the Clerk of this Court eertify to said Cironit Court before the next ter thereof a copy of the record in this cause.” This motion was fornnded ‘pon the petition,affida- vits>. and bond of said Defendant and order of the Cirouit coert of the United States for the Western Dis- < trict of Nerth Caroline,certified copies of which were filed in the Courtyand are a part of the record in this e Calse,& certified copy of which the Clerk of this Court will send wp as part of this case on appeal. The Court declined to sign the Heder, and made the following entry on the AGokee. bo wit:"The Court declines to permit the removal of this canse to the Cirenit Court of the United States,and declines to sign the order presented hy the Defendants shana from this judgment the Defendant,the R.& D.R.R.Co-.,appealed to the Supreme Court of North Carolina. Notice waived. Appeal bond fovik he a. asi eee ee Rn ee | heed AS MB. 6. Keb AA Vir degrureuts sxegt IH Bupreritin— Qe, Oneene hee na Hog arti Worth 23/92 wad tprefy ne Moin sregptons Vie tore Fiery CBr se te Oel.nck yy +h “<P te Cémmission to take Deposition.—Printed and for sale at Tak Lanpmark Jos Orrice, Statesville, N. C. NOR S to appear before you at such sime and place as you may appoint, and. 464 oath ta examine touching all such matters and things as...¥°7 shall know of and concerning a certain matter of controversy in our Superior Court for the codnty ot eeethm. sishiiss surneohulimenenkits pending, whe plaintiff, anath Gchasntred. And the deposition in writing, by you so taken, the saine to transmit, sealed with your seal, to our Superior Court, hel for said county, on tne Lh hhcnrcay, afl, hab, heathy in leu, A Airitnens, Ce te , Clerk of the said Court, at oen [aaa Of Clerk Buperior Court. ? tr ee oc eae tate 3 Tim te | ame” padi « [= | (Drie dere We Yee pokn trary Kale L A shy Gok o ; ste peg Phaabife tha i ptdan~ Qed OX 1 wer (maine? Me At Bb fh wnattT yf innch SSS eee = 13 AQ ee an phn , Ahk: up e isa moa LL rr ) Msapurd re So, J Asmeo Aue. ee | af 7 ; hee. | a ae reg A Jon, ce \* NORTH CAROLINA, SUPREME C to be argued upon the transcript of the record from the Superior Court of Bicone ‘upon consideration whereof, this Court is of opinion-that.. ag Po ..-. 6rror in the record and proceedings of the said Superior Court. o the Honorable Court, to the intent that the.... 23 cost of the appeal in this Court incurred, 7 444 Dollars (8 LIC, and let execution issue therefor. to-wit: the sum of A TRUB OOPY: | ee Cormecug m Ce he hia ak chez levi. of he Cook fee Koen Imex, Go he bectia Aetak of ofirX Cncndoce 2K Arteceed tel by te " Niith wtb an a e a County, you cause to be made the sum of $ for Debt, besides the further sum of $................. our said Oourt at the Court House in wep Poe Monday in oy 2. 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