v3244-445

19

and on the Second Point, that there was no evidence of

any kind that the ship's officers knew or should have

anticipated that she could not see over the life-jacket

and would thereby be injured.

A verdict should have been directed, and when it was

not directed, the judgment should have been set aside

and judgment n.o.v. entered for defendant.

Respectfully submitted,

Wood, Wood, Tatum, Mosser

& Brooke,

Erskine Wood,

1310 Yeon Building,

Portland 4, Oregon,

Attorneys for Appellant.

APPENDIX

Page References to Exhibits. Rule 18

Pages of

Exhibits Transcript

Plfs 3 "Presslines" 39

Def's 6 Stateroom Notice 98-99

Def's 7 Coast Guard Regulations 108-111; 116

Note : One section of these, of-

fered by Plf. 116

Def's 8 Life Jacket, offered by Plf. 42

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