Document Title Page


United States Circuit Court of Appeals

For the Ninth Circuit

The Pacific Telephone and Telegraph

Company (a corporation),

Plaintiff in Error,


Frank Starr,

Defendant in Error.

y No. 2242

Upon Writ of Error to the United States District Court for the

Western District of Washington, Northern Division.


The defendant in error has presented for the con-

sideration of the court some propositions which may

not have been suf3&ciently anticipated in our initial brief.

We therefore deem it proper to present the following

in answer thereto: It may be fairly said that counsel

has not neglected to present his case with ingenuity

and some plausibility. It vnll be observed that he

makes his case depend upon the single thread that

Smith (called the foreman) directed the plaintiff below

to use a piece of ladder which proved to be defective,

and that the master for whom Smith was working is

therefore liable.

archive.org Volume Name: govuscourtsca9briefs0798

Volume: http://archive.org/stream/govuscourtsca9briefs0798

Document Link: http://archive.org/stream/govuscourtsca9briefs0798#page/n572/mode/1up

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