xt70zp3vt865_161 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/mets.xml https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46.dao.xml unknown 14 Cubic Feet 31 boxes archival material 63m46 English University of Kentucky Copyright has not been assigned to the University of Kentucky.  Contact the Special Collections Research Center for information regarding rights and use of this collection. Harkins Family papers Mineral rights -- Kentucky -- Floyd County -- History. Law reports, digests, etc. -- Kentucky. Mining leases -- Kentucky -- Floyd County -- History. Practice of law -- Kentucky. Bankers -- Kentucky. Banks and banking -- Kentucky -- Prestonsburg. Coal trade -- Kentucky -- Floyd County -- History. Lawyers -- Kentucky. Blevins, Martin (administrator of estate of J. Jackson) v. Pitts, J.L. et al text Blevins, Martin (administrator of estate of J. Jackson) v. Pitts, J.L. et al 2016 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46/Box_18/Folder_15/0001.pdf 1903-1907 1907 1903-1907 section false xt70zp3vt865_161 xt70zp3vt865 United States Circuit Court,
Eastern District of Kentucky,
Sitting at Catlettsonrg, Ky.
Martin Blevins, Administrator of
Hetate of James Jackson, Plaintiff.
Vs: Amended Petition.
J. L. Pitts, ete., Defendants.
Per. 1.
The plaintiff, for amended petition nerein, abuse and statws:

The decedent, James Jackson was employed and assigned by
the defendants to work with, unter and subject to the orders
and nireotions of their serVant, John Turk, in the blasting
and removing rook, which was necessary in grading a railroad
had, wqioh work the defendants were engaged in and carrying
on at tee time of the accident and death of plaintiff’s de~
eedent, complained of.

In the blasting and ?9ﬂOVlﬁg said rook, it Was necessary
to use dynamite, fuse and powder, all of which were used by
:eia Hurk oi said decedent, and furnished them therefor by the
defendants.

The use of said dynamite, fuse and powowr is extra—oroi~
nariiy dangerous and hazardous, wiiox yes Known to defendants,
and for the protection and safety of said decedent, it was es—
sential teat defendants employ a skilled person who know the
oonposition and nature of said expiosives and who knew the
effects and results from the use thereof, and how to use the
eawe.

Said John Burk was not so skilled, and did not Know the

 the composition or nature of said explosives, nor how to use
the same, nor the effect or result of the use thereof, and was
in this respect and otherwise incompetent to perform the duties
assigned him by the defendants. in adiition to being unskilled
in this kind of work, the said Burk was a reckless, neglecttnl
and careless man and was unfit, inconpetent and unsafe, for the
protection of decedent and the others working with and under
him, in the said position.

Before employing said Burk to do said work, the defendants
knew, or by the exercise of ordinary care, could have knonn of
his unskilfulness, recklessness, carelessness, unfitness and
incompetency to do said work, notwithstanding which the said
defendants negligently and carelessly employed the said Burk
and negligently and carelessly placed him over said decedent,
and in the possession of and directed him to use the said dan«
gerous 6XJ1081V63, in the blasting and removing rock, as afore—
said, which he did in a negligent, reckless, careless and un—
skilful manner, th:reby bringing on, and causing the said ex—
plosion and the death of said decedent.

The accident in which decedent lost his life, complained
of, was caused by the unskilful, reckless, negligent and care-
less acts and conduct of the defendants, and said Burk in the
prosecution of said work, which accident would not have occured ,
if the defendants had employed a skilled, carefwl and competent
servant to manage said work. The said decedent did not know,
nor by the exercise of ordinary care could not have known of
the incompeteucy, unskilfulness, recklessness or carelessness

of the said Burk, but believed him to be competent and capable,
and by reason thereof, proceeded to work rith and under him as
per the orders and directions of defendants, thereby losing
his life, as aforesaid.

 After said Burk was so employed and placed in charge of
said york, by defendants and before the happening of said ac—
cident, defendants negligently and carelessly refused and failed
to discharge said Burk, out retained and permitted him to con~
tinue in said work, up to the happening of said accident, after
they knew, or by the exercise of ordinary care, could have
known of his said unskilfulncss, carelessness, recklessness and
lnoonpetency to do said work.

Par. 2.

The defendants were further careless and negligent in this,
they negligently and carelessly furnished said decedent and
said Burk insufficient, defective and unsafe tools and appli—
ances with which to do eaid work, and negligently and careless—
ly failed to furnish said decedent and said Burk safe, proper
and sufficient tools and appliances with watch to do said work,
out for watch negligence and carelessness said accident would
not have occurred.

The plaintiff says that the said accident and death of said
decedent was brought about and caused by the negligence of da—
fendants charged in paragranh To. 1 or paragronh No. 2 of this
amended petition, out plaintiff does not know which was the
primary cause thereof, but one of said caused did bring on said
acci‘cnt and death; and he charges that both contributed to,
and helped to cause said accident and ~oath.

Wherefore, plaintiff prays for Judgment for Ten Tnousand
Dollars in dawages, prays, as in original petition, for costs
and all proper relief.

C. B. Wheeler, Attorney for Plaintiff.

 \ , ,
\v.
- United States Circuit Court,
. Eastern District of Kentucky.
Martin Blevins, Admr. of the estate
of James Jackson, Plaintiff.
Vs: Amended Petition.
J. L. Pitts, dc. V Defendants.
For amendment to original and amended petitions filed herein
‘ the plaintiff cones and says:

The appliances furnished by defendants with which to do the work
charged in the petition and amended petition were deficient, unsafe
and insufficient in this, the fuse furnished and used had been ex—
posed to the weather and hot sun for such a length of time as to
and Which did deCOmpose the sane, and thereby render it easier and
quicker to burn and explode and more dangerous for use in blasting.
In addition to said fuse being furnished in this decomposed state,
it was cut in pieces of two to three feet in length and furnished
by defendants in these lengths or with instructions to the several
foreman and the said Burke to so out said fuse in such lengths to
be used by them and him in said blasting and it was the use of this
short and decomposed fuse in a ten foot hole that caused said ac—
cident and Killing.

The defendants were personally present and superintending said
work by giving orders and direction to their foreman, and, inau—
gurated all the plans and details of said work; that it was a part
of the plans and orders of defendants to said foreman that the fuse ,
should be out two to three feet long and so used, so as to save ex—
pense to them, and the said Burke was undertaking and attempting l
to carry out this order of defendants when and by reason of which
said accident happened. a

 The said foreman Burke was incompetent and unfit for his po—
sition in this, he was harebrained, hot headed, daring without ex—
perience, and had no knowledge of this kind of work or the safest
and best way and manner in Which to do and carry on said work; by
reason of which he went about said work erratically, using this de—
fective and short fuse with which to shoot the blasts, all of which
caused and brought about the accident and death complained of. he
caused the accident by drilling a ten foot hole in a rock cliff and
loading it with a large amount of blasting powder and placing therein
this short and defectibe fuse, after having set fire to one end of
it, before he tamped said hole, risking the possibility of being
able to temp it after said burning fuse was placed therein and be—
fore the fire could reach the powder and cause the explosion; after
so placing said powder and burning fuse in said ten foot hole, the
said Burk ordered and directed the deceased Jackson to remain for
the purpose of tamping it, which he did as per said order and while
so engaged the said fuse burned to the powder and caused the ex-
plosion which killed the deceased, all of which was caused and done
by reason of the incompetency and infitness of said Burk to do said
work, and by the use of the defective and insufficient fuse as afore-
said. All the causes of said accident and death herein set out were
due to and caused by the gross negligence of defendants.

The deceased Jackson left surviving him a wife, viz: _..___.._
Jackson and an infant daughter, viz:____ Jackson who is only__
years of age and neither of whom have any property or money out of
which to make their support, but depended entirely upon the labor

. and wages of the deceased for their support and maintenance.

Wherefore plaintiff prays that he recover as prayed in original
for the benefit of said widow and infant child.

0- 8. Wheeler, Attorney for Plaintiff.

 [M M EDIATE REPORT OF ACCIDENT
/ .' ’ / ’ ﬂ/
Employee 0j~/£////Z/k/ 7 W e ,W77WW:},7 ,, .,_ _.;/WWWWWWWWWWW,W___-_.._,__,, 7777777MVA—4wv—ﬁ'éiigr—r~—77M7—i-——;~~—; ‘
CONTR/B- i Carelessncss of injured pcrson?..,._...7._‘1//_ '
arms CAUSES. i / i
Negligence of a fellow workman/.., .7 ‘
w 7 / ..
[OVEXL] /// _' ,

 ("W ~ '
THE i Place,” C ;k¢r%\ ’ gamut g/gw ﬂ
ACCIDENT. i // /' "
‘ Statement of'injurml person.- /ﬂ "(30/1 3 (/f/ﬂ / 3‘/ ‘
x 9
H , § 1
m x /
‘ 3 r’ 3‘ /, / 4- / , a / 0 3
"‘" Q1“; \ 3” 3 Inscription Woof/dent by ellﬂ-Ivitibi:8%ﬂ(A{// ~/A[/ CJ/Q/r‘éﬂ 4‘3 ”L“ ax/Wp/té
: C \g\\{$ / /M.(/)/J{ 7/ ,1/( e%% A c ,.%91 w/{g/fé/{1a/(ﬂ‘Z/A a%///¢ ﬂ/z tw/%/£P€‘
\ N /’ / 7 3 \ //{, / / ﬂ /
, \ N EC: . %/,f"¢ ‘43 /’4 (ﬂ (/L/Méér /d//(C.//fl/%< 24a 11.4 cl/C M/ﬂ / [/u 176ng (:7 ///¥11¢/5/ff%7
\ 3\ K \ / ﬂ ,1 / / I," / {ﬂ '7” K ,
R. ‘\\\ W :1 [412% éféé ”/1 (A. Z L / (i W%<,C£%Z(vﬁ/sl»// {1.«ﬂﬂmctl/ /Q ngV/VLAw/ (/// k/Z 1 A// rﬂérﬂl’
3 (\V A ‘ , I ’ 7 / A, , ’ '
m ‘ \ \iV/t / L to“; u/C/7/7’4j -///- ill/1% ,, ”1‘“ I /:/-{17/i/ CI ﬁziﬂ (47“434: V \
u ,, " , / / _ ,, \ / ,/ ” / / ’ 7 3’
\3 //AC %4 f’l/V‘iﬂ/ (r'ﬂJ///§ (1 ’3 {c I I 1 ( 1L7 ‘ ("I (/ff‘: 0“ xl/i‘é 0'; g7? //)>”ﬂﬁ/ *////{ 1117/1/45 / 1/
~. /I /, / 7/ , 7 ,, / 3‘ . ” / // / , 3
S ‘ ﬂ/éf {c /p—u// Z/g ,7f4// (M/14,4 l’¢()("//
“ \ ~ N / ' 7 , ‘ 3 I M
R X § N '37 6/ ~— C/f/fo/gfééo oc/ZW M‘Arowfgég/
\J/ K 3W“; J limp/own

 ,_ ‘ . I
P H. c, CABELL CABELL, TALLEY 15. CABELL
ROBERT H. TALLEV
R. E. CABELL ATTORNEYS AT LAW
GEO 8_ WHITE SHAFER BUILDING
)
RICHMOND, VA. a.“ 21,190? .
Tlevibs v. hitts, Tankins ; Trnodle.
J‘Uo’rfe ". H’ar‘kins,
TDreeaw,( h 57‘1:r"“, ’T. ,
“car 7‘1'1‘: .
- n ., .- ._,\ ”7‘ , ., , +—
ﬁvr"r. Ta'ell wcvt '0 AlleoVaof tuuioo, g. did go”
sfnﬁye‘rnehts 0’ "r. E . Tﬁ'ﬁwll'w' {1‘65 A. V . “W“‘ex‘t as “*0 tr’dra ex:—
cident, CCfiﬂS of x 10? e enclose.
”a presuwé “(u Howe a“ ocned all t“w xi nesscs,aod if it
176716 ”or: "‘-r:Cr:‘.:.»iiaY“7 ‘Lr a(‘V:;~.:'=<::e ‘.i‘oe“ 71313711 in” ft sewn-e 1+1».ij-
a‘fF—rr‘xaoce, 'e "'cv’ld flank j C7" fr: do so and. 3 "ill rei'vv’wrso
you .
‘ r. Haﬁell caxrects to come t ‘7a“1e",'as;?1_xr:j M aypm-Lu‘ nit“.
j??? 17‘, ‘f‘we case.
Verj' fly" 17' 7'01: ":5, .
y w

 ’ O

Pi‘ ‘fb ' "Wigi'x: hlcvi‘ns.

‘St 11?: ‘_":tb of “Witnesses.

(‘., 77,. $5711.21] ' 117;» T. : Zia": 11"", "I. .‘,'... .:.: veri; I 442:; N. QT“ c x,
can) in :‘-1:"-::‘ .Turksm“: my} “mfg-e ,'31"C4_:(JL. ”i, is, 7.116”. 7— "1‘1 {Ho
‘ Hi ‘1"! miles of work, xi Laugh. I ’Irz‘lhfli'ih 5.7th Lu c7111": :3:"
t“: 91011-5: york. "‘"a 2”,:"334"; 1’70": 71) to 100 "1';; in " .i' cup. I _
'ul,; ".nci;e, aid Trrk r f.o ’oss of a ':5r. “urke h:d ll or 15
in ‘Lis ‘.. 91o :;.; pieces, sous drove carts °.,:-,. “may: iii '1‘“ :5,-1k
i 1:‘. "a: :tor'w: :5:"?!ng and 5a,: ‘:1: <1 ""'1'31‘ Jung. '2‘.: iii lord on:
“of ‘ ,' ..:; ’ is ”Amid-cos. "is drilled 2‘13 Tales. F'X‘. 71.5"“;721‘:
Tin-ad Turks, is :1 '“ . -~-,,= ‘: .‘::fﬂmi ""5 .Tm"'i: a“: Ellis,
“ohm" 1‘s. "e as a "or": 21.3”: “'1‘ ‘. T TWIN: l’we: in This ~‘\“,{f_‘i 1‘
ECU :71 ; gears. “:13“; .ux‘fed *"01‘ “it‘s, "in "ﬁrm "- "1"1"1.]uli', w.) “01‘
1: 7.1T» (7:7. 1: Gt] rim, 1 also WI mixed for" .’::L—Lisxzc, Writ s
°-- ”its. IMF-‘.:»: we sent ‘.0 or: "‘1.." ."l‘. ’11:."17-1‘ics. I f‘mlm‘lhi": .:‘t coyot-
co ":;m. I PITT-2“" he took «1 drii}: 31'" ‘.'.‘ziskeny, hut harm by; .' “in do" it;
on ($01k. T latched 5'13): all closely. Tf' 1e ‘_lr;'.::d:-.d 27-, mm 3 save
3‘1"!) :9.‘:“':o1‘:}.“3f 50 Eire u, "xxx. and {lee "o ”3:; '. :;.“ i“ 13"1 no"
rtiye satisfactory york. All Port-3mm. “mare rule ;J‘ivilere. I did no:
:—.-,~_;»: the ':xzci/isnt. ”10‘ i'i't‘ere -_>"T"‘ITA; :,r_“ﬁv:,21"«'ar‘l:ru. "To bar”: :1 r ’10
strin" not as Jim, and the "TC-32’] crm either use “is: 7' .‘. Al; Or a, »1
fuse. T'Je..jr 5"f;‘*1::t1";—Cll}“ use the lint/ﬁery“ to sorta" holes, i3 allzjs '
use ‘2‘.-,2 '1':;trer~r “0 fire holes. I713 'Frix'evr‘..':‘1's duty is ‘.,-0 load Holes.
The :JC.»"d';-,l‘ am}. fuse is river. to Trim. "Jr: rive the "c ': ‘1'?”th “:3
asrs for. We laws the quunitity to hit. They :snerally ask for :2.
box of‘ number: dyna its and a coil of fuse at a time. Tie Foreian
.vould :11;-rags let 1:: know: the night before, has." much poxy'der and fuse e

 , , ‘
.
#2
iﬁSUﬂ
. h? (ouli 356 the neKi Amy. I SWUTLXKSKixx him a Slip #0 tie
COmnids%ry clerk. We had a ﬁlm to txk? fl: Qdeer Lox" egﬂi :trﬁing
in a Eﬁok. Each “luster ?uﬁ his fns: fo suit dimsel*, also fhey
;1011111 $ue ﬁfie j‘ld‘fe G‘P ﬁ1c-7 run-;Vg ;,c.ri::r fr\ g>1ﬁ iv: '1 ‘10}.e. 'T‘Li 3 12:5
the “my Burke did. Turks and Jackson ‘V‘L-Ld hijﬁil’l ".'Or‘iit‘f" tchez‘ier {3 or
4 monfhs lxaadiﬁﬁ holes. '[ nev:r Qid @WY anmylaint Frovg‘y1cﬁ. Oxr
material 715 fhe F9s+ we could zxfe. We cat The pﬁvder and fuse
from F i t t 5b «.1113.
(g) G. H. Donnnllsy.
A° 3' RVT33ktK livfé EiSt pgip’: KN. b mica: I Vub {Graham of Taﬁﬁ
:‘zlxgaﬁed it: fii‘ﬁdifif, and 73.5 101% iii” $00 or wn :';1”(_ib from .Tgmﬁghgjg.
JLL’LfI-Lbﬁfl ‘.'/Cu‘kesaii !“Or‘ '2: a 7715‘}, ‘3? 5 1L l .,7’JCIWi’I'. Wu‘kr; nan/.31" .w>1‘~;ed Fwy
,n:. "a km: : ‘mrswuﬂ like myself, add {c vorked tovctbcr ”or & vhile
Burk: Jas m5 fOCd a ran as Jas on the road. I had kqovn Him Hefnre
he Came on this York. "a vmrked ”or Tgwxinvs aﬁﬂ Ellis. We ﬁnd no?
a ra5ﬁ12 Prainsd man it all. Hr waxr iii ElaatiIT 91 7. TV: ;Dvdcr
ard p“‘5, p”?Viﬁlﬁd 15 718 the “est ﬁO he lad, 40$ dynaxiic and 5 ;1y
tape fUSe. T13 wwﬂ *Hit 31d ﬁde loidiné rot %Cfﬂ ﬁﬁc pavder qu fuse
P"ﬁmv5he W3"&Ziﬂﬁo A box or tyc Jab Iouﬁht For wand of 45 avaff day
Th3 r153 Uﬁﬁvs in 50 Pﬁ“* nails. 0?: or £70 0011b is ”chH @203
Ilmatsr mﬁd Ede hlasfcr nuts if in prewar 1cﬁ*53. T adior lad any
OI“1cT 9'0712 "ﬁthiJ1* f"ze ‘3M3%, aac‘: liLst n? a‘1t {fie (way: TO :y it ":ic~
b‘J—‘f‘c T, L. is flat T $4.1 7'12’3 1‘13. T 30%“. 1"1.\,'.f:_i_q:f bﬂkyonlfj 37793 '.«f‘f‘idu'flt
I ifli’ﬁC it {1.159 [71:11” O 13'; (' 11"v::1_~}a;)‘]g:,5, _T.A(}'Lj5/_‘,'n_ ‘,’;n 013;]. o-P ‘:1?)va
f311rvvs f‘JLt ‘u1ows :EVuTQthiq m I “Jiwk ‘ icy Haaﬁa 30731 A L44 1 #1 (Q 11 1.(/_ {-4’ 7r («éf ,,., //(<.- x. , " K 1‘1/r r’a/ // ﬂ.d_ ‘ I,—’A'lpM/'(La a+(
((1 / 4 I/ ’.. . /
C, { t .94 (,4 LA y » 4 < ‘Z/, k < v 1 <- -, 4 .1 ,.. 1 1 4‘ '- . 1 L// /‘ 1 - 1 «t , .I < r ‘ ( ("i/’.: /A: ,yv /( 6' (2 1.1; «4%
a ‘ / //:f// ‘ , ’10 ,. 1 . /_ . /
' , , r’( 1 1V ( () I" 1"? /(//' ‘ ” ' ’//V ' / .4 / / - ;- ,, If/lax/r,1/1 Av? via (my%,.
.7 K4 >/_ A /1 (V L/(// ’2- < f é< /( «(At t,/ {(1 /' // r 9‘ ./c /‘ 1 , , A ﬂ / ,4’]. /’j f
. , ‘ ' ' / ‘~ , z » '4’“ (1/ 4 v1. 1, , ’ '7 ‘ 4“ 7/
l//} r! (‘7‘ f/ ‘ 1f /' r/I / z' / . . 1 , ,’ 1' . [,1 / x?“
'; L7 » I 6’ 47 f ‘ . " l } ( a 7/1, "‘V” ‘L / /"/ "~[ y / //" ' ‘ ”I ( r/g' /’ a z—(. M/rnty
. , , , , . /
,7 1 ,1 ‘ ’ .
., 24 , l/ , >1 - ( /, / / 1 ./ 1 . ,
o Fig/kg \. .ﬂ, 1 / «(El-a // rﬂ 4 ;'/'/. . . / /, (0 "404/1 1 ﬂ ‘-( , //«L "f/r-rnna/«lé
/' / / ' l , ’7
, ' { '- » ,. A f I ’ , ( .. 1 . , . .1
I 1 / a 1’ r ( ’// I // // L (f/ 9f , r .» «4 (.,7; . ///I g ,, ,/ , / _ ’7 ’ a [.1 ( ,. ":1 Kf//6/¢r,(£
. (ff //(¢ ,.7..,.,;(/ _ (a P/ / I , .. 7
/ ,. va z .1./. , / 1/
/ , , ‘ r / , 1 L ( ( K , <- r1 } , , . ,1 r , 4 /
e 1 J x K // y (I / /‘ 1' 1 ~ . /.1 < w (,..
e . « (7 r ( (A .1, .“ ‘ I 4 ' / 1 ,4 ' . __ '
/ / //, / r11 [V/f,’ .’./(7,» .11 /.‘y {/1//«_‘( /r/m o,//.J//(\MZK;
{1 ( . ( , A 4 ~ / , 1 . ,
/.i {‘ ff (Ill/[c r ~4. A/ ( 1c r ,” 1,,” it ‘L v/¢,( /’ /,: fl/fd/ <4”, r’a:
«Wm/x- /1 / / 4 .7 .
V . I 1, / / /é / / ‘.. J.
I ~ 1 .‘ 1/‘71/1 I ,< (r ,« 4 1 1._/ 7 ,.,, l. ,1/,,. .1 /,, (’, I ./’/n ( ,. ””erer
> / r/ l e 01 /( ‘/*' K 0’ ,7 1 r ( 4 v ( , ’4 , ‘ K/ \m /, /‘ f1 / , , ‘ ‘ 4 ('.. ‘ /
r7 ' 1 .7 ( ﬂ ‘ ‘ ' ’ ‘ v a 1, 77%. V’k’wv (491’ “~40” ”MC/24194
, , ,U +1 <47 5L . 7’21 1K/ ; r { / [/1 1 ,
’ R1 . {N ‘ , , . 1 ' 1
. . _ r r/ a Q r ”v ,r , , , , / A I . i/ L / A! /' (fr/{4’02 074.7“
/ F r z / ‘ /,I1 / , ( 1’ ( / "" ( / 11).: I I 1
f 1 , ‘ I ,. t. “(I 14 1 av , / 1 < A /(. f ;’ ’ i I/ (9.. 6' , K/ 1
‘4 */ I "“1°-/rA/( Af/ r/I / I 11 ' (,4') ”dug/2’1.”
‘ / / V (f [r , C {1! ,r , . ' ,.
,. / , r 1 1_ A ,7 L ﬂ . ’ ,1 , .1 A .
/ .//' 71/ ' ' (/ .34 < ,1. #747 7x5, C>
// I f) 4Q L€’/‘:((’/r(/y //(¢ a—/(r~ K” 9 v ( / // . . ., .' . , /, ““‘ /r/
I ,1 ‘ l
{v r , 1,, :1 3'7 , /
1 I/
// /‘ ,/ , ., / / ’
ﬂ/l ;
/1
e/ 1 ‘
x t r
-V ,r 1' r—r/' /.///4 r‘ // /A( %»’/I . 1 / //( 4 (I . 4 y ' / , ' ,‘(. ' ‘ ’ ‘/’ «I f ' / ’1/ ,,//
/ . / ' - 1 .
, I 11* ( r' ‘ , v (- ‘.;. ,/ ’/'~/1 -«' //(’»—' ”’ ’/' a ,, I (,1 ' ’ 1/ 1 », {,7 r’rr /’/<1 x7(v/r-¢/',,4,//
/ Z /’ /' x’ // . 7" '
r U c / «’g ._.1/ 1 1 , /( .“4 (1» v ,1 »/’/.' / . . ,1 . /' A
, / , / / yx’ . ’.A / . ‘ , I . I _) ., //I /( 1/ l( 1’1’//,/
O l t a / [/7 V ' 7 I H ’/' '1 /' " ' " I f " / [I ' 93 " f7! //'( r1 - .11 1 "0%, a/ aLééaﬂ”

 6 .
' ‘ _ 7 r ‘1
, J . L. P1111 S,
IRAILIKOAD CONTRACW‘OR,
SCOT TSVILI :13, VA . ~
/ / , /.’ ﬂ ’ v _,
.LN/-/M /, /"/ ,,.(,/,,./ o/ /w .// / W/M/;//
)1 /,, y/ﬂle //,/ r/V’,’ ’. , , « I _ I ,1, I [/I, [Ll/l, , , / “M4 ,r: ,A /'/:l;a ,, , ’ - , , /irl //
\ 17 " 1 ' ‘ w) . Q ’ A-
(£141; ") 2Q /« ' ( ‘/;%( ( ,x/ / ( 1‘ // r’ r r ,, , . / A L/ / /" ’ " ’ / / ( ,— //’ ['4 "7‘11er
‘ ' 251/ / / ,7 ’ V06 5‘
/ I ' j a '
ﬂ ,7 -- f
K N / ﬂ ’ ‘ ' “ / a / /; ,. , ‘ //, 7 ~ /‘"’ f/
" , , / ' , ’ , /, ‘
/ // . ,, z , , f (r K, y/ ,. . 1/ :1 , /0
/ 17 / f , A , / ,
o c //// , ,/‘/'/ ﬂ. / ( / x (I , / (7
.,/f / ’f ’p /{r{ /I// .r f
:7 11/ / [I ” ﬂ /( ‘
I z « r ( 4 p/'/~ 7 ,
,/"//., _:/ /, r, f
x f / /'/’/ , / / e
// x/ , ."I ”// f (1:4 I / , ' /
K 4 . '
I /’ / «(An/‘7', ,7/ "'
;. 1' , , (V, . r/,/// (7( 1 , /{‘/:y /; "(I r/r/ / , // / / xc /
/' ‘ I , 4 / / / // ’ , ,, V' H ’ / ' l /
/, / /' / ’ ’ U , ,
K ' ' / ' ’ ’ ‘/ « r . v 34/ f « o~ // ‘ /
* , , x
’ f / / . , r »l /' r I 4 « F , / y,/ / 9’
z, , , . e g: / ,/ r (I!
,/ ~ .. . /
, / , / I, ,, , / r , , f), ( y 1 "

  ‘\
State of Kentucky, )
) ss .
Boyd County. )
The affiant Martin Blevins says he is old 3nd feeble and lives
about fifty miles from Catlettsburg. He has no ioney or property
in his hands belonging to the deceased Jackson and is poor himself
and is not able either physically or financially to travel. “or
these reasons he has been unable to come to Boyd County where his
attorney resides for the purpose of prepareing and filing this amended
petition sooner. He says the statements contained herein are true
as he believes.
Subscribed and svorn to before me by Martin Blevins, this__ﬂ~
day of _“__.’___1906. .__...___.i_______ii__iu“.i________i_____ * ‘1
United States of America,
Eastern District of Kentucky.
I, Joe. C. Winnell, Clerk of the United States Circuit court
for the Sixth Judicial Circuit and Eastern District of Kentucky, at
Catlettsburg, do hereby certify that the yoregoing is a true and
correct copy or the amended petition filed in the matter set out
in the caption hereto, as sane appears from the original no? on file
in ny said office.
Witness my-hﬁnd as Clerk, one the seal of said Court
at Catlettsburg, this 4th day of April, A. D. 1907
and of our Indepenoenoo the 131st year. >
Joe. C. Finnell, Clerk.
Wmérfiii} C -