v0815-435

Document Title Page

(o

No. 2266.

IN the;

United States

Circuit Court of Appeals

FOR THE NINTH CIRCUIT.

San Pedro, Los Angeles & Salt

Lake Railroad Company, a cor-

poration,

Plaintiff in Error^

VS.

Martini Davide,

Defendant in Error.

BRIEF OF DEFENDANT IN ERROR.

STATEMENT.

On the 25th day of April, 191 1, defendant in error,

hereafter referred to as plaintiff, was in the employ of

plaintiff in error, hereafter referred to as defendant,

in the capacity of section hand near Caliente in the

state of Nevada. Upon that date plaintiff sustained

injuries resulting in the amputation of his left hand.

The second amended complaint alleges fols. 32-33

that on the day in question plaintiff was engaged in the

repair of the main line track of defendant and that


archive.org Volume Name: govuscourtsca9briefs0815

Volume: http://archive.org/stream/govuscourtsca9briefs0815

Document Link: http://archive.org/stream/govuscourtsca9briefs0815#page/n434/mode/1up

Top Keywords (auto-generated):

car, cars, speed, track, fol, work, negligence, accident, riding, preceding, engaged, collision, camp, slackening, main

Top Key Phrases (auto-generated):

car preceding, section fore, interstate commerce, forward car, accident occurred, ver dict, quit work, negli gence, forward cars, forth fol., fellow servant, camp fol., 199 federal, witnesses clearly, wisely applied

Document Status: UGLY