xt70zp3vt865_251 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. Laferty, Robert v. Cliff Coal Company text Laferty, Robert v. Cliff Coal Company 2016 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46/Box_24/Folder_4/4307.pdf undated section false xt70zp3vt865_251 xt70zp3vt865 33:9): 1.-
Floyd Circuit Court.
Robe3ty Laterty ilaimtiff
vs. i‘eti tion;
‘ Cliff Gust *nioauy nefendmuta
gag nlqijtiff states that Lne defunfiflnt. the
Cliff Teal Courany, is W CDFUOT?LifiQ, inosrujr ted by the
1%: S c3f the fit=Lte c>f flnribicfi y, o31d i3s sniCIL has; true ad thox'ity
to ccntrmct and we centr ates ’Atn, sue sue be Siéd in its
COTD(Z\}“"”{;”E nerve, 3121'? 1,5 ~“..L3"1€3, onrfiu‘aze, tell and 3312310093: of
‘ cowl from it: aims, in? La do any amfl 331 kinfls 0? business
as a cwrnormtaon an er its corner to news, The Cliff final
Cemrnny. 3
She defoudflut, voherty Liferty, furtnez 3&33
that hereto?ore he “33 been emulsjed by and worked for the 3
sxid filfiintlft in ntnlug mun fielivoring e331 Form toe o%nks
V in tannins on as the Jain Lian or entrafloe in the said coal
00313732332737'3 “liar? 333.91%: it its onera,t;i,x13£ amt? 33.23:; 32(23):; op.~,3m3,{,i;3é;
near fllfi. Len=ucKy, and on the Lhtn as; of Lovemaer, ljl}.
tigit 333 ti;e c {.83;“S:?n5‘33 rain? Tlfiy‘LIQIQiIC?‘ 31' Lr=e e 1133 (39*31
Company. its servants. fluent; EJG ewplsyees tnmt his right
hand, mzn tofi fingers were can ht by one of the mining “are
.3333 me and other enolnyees were Queuing 3 can out Frpw ;ne of
tme rooms or entr 309% where he use snetaing in Lne coal mine
i for the said Ulnintiff; that “is $311 name. arm eufi especial-
ly his ring finger on “is right nanfi was out, singled and
bruised to mush an e.H{:J‘llL
2i,)e.‘2:1.'5.~'2-'32”‘::': inn (‘.-2:11, 02.2“ 2.31:“! {3 (22:-'24:, 12.21121) Lira/'1 9.22.221 rér‘rtctm‘i 1.21 221:5
r0425: ~.2. 23.2.0271. distance: in fr 2.21 2.11252 @‘r1t"r.'-2.2me H.219», 22,1123 t.;2?2’..’L ”my
the c;‘2,.'m2}1-"2.~3~[15,2329 ”2.2.1272, 1'L8r1'71{«’f€‘!a(‘f0 as: :-2.f:.)r':—‘-s-92.i:i of km; 9.2.1.2? 123.2171
tiff ix. '1..‘f_‘1,.2,,.2-.‘L.2.;r:5 s.»:~':.ir'i watt 1;.; rct-zrz‘win {were 52.12:? . 2.32.2.1Lng': Uncut: it
‘72”"9 in E" 2‘7"}2215'51‘WJLIE Digititjxm fir ii. a ':‘21’22722-7‘. ::fi, .2.~'~:r.rirf£:?”
‘f‘ufii. 1:22.227. 27:275'22 .t ‘L.:e: “J":ozti. 22,-J27 Li"e.i:7..€~. {..:2 (122.10%; mm}. 2121171,
.3016: of 'r<)1"}..32e2.:1 or it}; 2 "1‘2 2.,1i31,='s‘«2'1c6: (.3129); (‘.-3.21:]:
...-.225: 411025.21 of L..-:69 23:21». 2:1" M21. Liv:- 32'112‘: maul. (Tilt-WT: 1...: :::) ('24.:12-211
its". inf—2.2. Too 1:, Lacs-5' 2.1.23.3. "a.T"%,o:.w:23 L;.. L: rec-r7121 :.2.=i‘2'.'.'12:.:.1'1. (6‘1.deng
I 7"”22‘16". "$2223: 1"‘221‘50 1:2; 1.2.212 L“r(]c Jaw-1 r1‘%...7.i§;s:ni. 1:222:91" rue defend
ain't, ‘.:'?!T‘E'i, 1.2.2“ Frau-I: 13.29, s;:n;1.‘2;2:xg. in the F: J 0521‘s, 2..;-c L115;
13*, 1522:; 93.3%“. 122133;.3‘14::::? 1.2.2121: were; .; 1.25:2":1162‘, (‘2‘): 'L..::: 236:1'“::1t12~.211,, its. 991* -
. wants $112.12.? 2;“ .22.}...2ym ‘.....21-3 2.2}.minl.ii‘i‘ 3,222.3 initiraéd .“2.;: :u‘:.z‘srs-.=.:-2.ir.‘a.
“."=.,.3.i::1.i.f_‘i‘ Cambiwi" 533.322: that Slum i!i.jlll"i"~‘.f.‘ here-
it17)€§1('2j‘.T‘-“ CL);’)‘."72’»‘-.;11€‘”, 011'“ 72.1“?) -‘:t»;212-1';..3,er?.’t; ‘Liv‘li; tub. :3:1.;::.;'2'2 to 111.31,
12632112321452" 12.22:: 232112), 721.221.125.21 mi‘; ::;,z‘f'f‘t=ari;‘35_i. ‘L.; 1;. 1952.535. 0
'J‘.r',s,oas:'-2.J:ri :"r2‘1'3 ""."t", {.:i:-9000.00) 3..-2123119 may? LIN-2. U}; ':;im 9’12".
l3~‘i‘»I‘E?lé‘£:‘:“‘-Tl€‘?£:£t 7.1271 hf": '_‘2_i;f"ra=t1cea of tam 3131-13 23rei‘(2-s‘x".drz.z1t -::0=:m=x'iy tum
:’-.2"= 1272:121cua.;94:2-1 my Mm :.‘:efimulant 20 ..'}..922122416; 51:31.7. :.Lrszt: ,‘.200-(‘5001
.121‘ ‘ff‘f‘L,2'-..:.-, i-“l,“12;:;if“f 12%.”.iyix fizxfigr:21<>521t "if/(3.271531;
the deferulxrx‘t; 2:1 the 521.12. of. 122m) ’:‘houzsam’: 3120119.:‘3, and for
cost and all Europa“ 3.21:1 '3.3*2:2rcnrirxte relief.
I ' .»‘Lttys. for Plaintiff.

 1.2“? i i o
State cfiientucky.
Floyd Cc:;:...1ty . "it.
live i':.'l.r7aintif'f, T'Zo';:>ert ..i.»':z,f‘e1"ty. says that I
the skater-rents of the fcrsgfihing netition are true as he
believes, exceot as to tee. atmcuv'rt o i r?:z:11:3,§“;9$ setfnrth
therein
flimscrioerl and sworn to before he oy :«ic'cert _
lei‘exvty, this the 7th :.Zay of ,"lz'ovember, 1.914.
It..- - unnm'l‘ we” ”Maw-”1*”

 {?
I
.. Hoberty Laferty! .
Plaintlff.
V S . P eti tio r1,
qhe Cliff Coal Co.,
, Defendant.
. -, 1', :’ ‘; (55'5"? 2“, / f . [..5 5X (.‘3,
- 5
.. ‘ _ K V‘frffl;_r’;,5 a
‘ 1’ ‘.5 : " L s ‘L _wr A ' 5,:, .:‘»; .3 “‘25;
5 \ 1' :m_ A. // [ng ,4" j” ,
I ‘5 . r‘ f , .’:,: ,1}?sz - ‘1'! .:’ 1
: [V 55...: .:5 ‘1

 THE CLIFF COAL COMPANY
——~uNERs AND senppansei
‘ TN; MILLERS CREEK DISTRICT KY. BLOCK WES.”
”“221":3? 4...... omas— .
-—— PORTSMOUTH,OHKD W"TTT“‘
. May 10th, 1915.
Messrs. Harkins & Harkins, '
Prestonsburg, Ky. A
Gentlemen:— _ ‘
~ We are enclosing herewith statements I

of Messrs. B. G. Hughes, Thee, Blackburn, Wm. Blackburn
and Herve Hunley regarding the suit which Robert Lafferty
filed against this company in your courts.

You will note the H. H. Hunley statement
has been signed by him. The originals we have on hand.

' We will continue to obtain evidence in

this case and submit to you from time to time.

Kindly preserve these statements and
oblige,

I Yours truly,
THE CLIFF GOAL 0 OMPANY.
H‘:" ’.“ President.

 May 4th, 1815.
STATEEENT OF WM. BLACKBURN.
hr. Dan Woodruff informed me about the same

day that Mr. Robert Lafferty told him (Mr. Woodruff), that
he had hurt one of his fingers by getting it between a nine
car and a lost used as a safety or nine grey, and hr.
Woodruff requested me to take a sledge and knock the goat.
down. i

» I went to the room where Mr. Lafferty :
worked and wheresthe post was and on my Way there I picked
uy a short piece of plank about three feet long and not ‘
having a sledge hammer with me I thought that I would try
to knock the gost down with the small fiece of plank,
which was about one inch thick and about three inches
wide at one end, running down to a point at the other end. 3
I struck a nedium blow against the goat with the shall :
pieoe of plank, and to ry surfrise the goat fell and L
jarred the small Iiece of plank from my hold——which . ‘
caused me to believe that the Iost was just about standing _
and a very light tap or shove against would knock it down.

 1. ?~
~ ‘.‘ ‘
T'fay 42th, 19,-1'15.
STA.TE3L;I:€LE£T CF 5‘». HHI’IiL—LES. .
, s
As best that I can renenber, Jasger Eullins ~‘
told 1::e that Joe Jalullins ran against a Lost and hurt his V
sl‘roulrler, whereu1.on he renoved the “post without consent .,
from: any of the Conqany Officials, and llaeed it in the I
joeition that it was when Bob Lafferty injured. his
finger by catching it between the zest and the car. ’
Jae-yer liullins told me when Bob Lai‘i‘erty ‘
told him; about hurting his finger tl'iat he (Jasper Eiullins} ,
( threw a snail stick against the lzoet and knocked it down.

 May 5th, 1915.
STATELENT CF MR. THOLAS BLACKBURN
L It was my duty to undercut the coal in the
room No. l on 6th left where hr. Robert Lafferty worked at
The Cliff Coal Conyany.

I orerated the Sullivan cutting machine and
when entering hr. Robert Lafferty's room to ylace the
hachine at the face of the coal, it was necessary for H8 to
gass the 30st which hr. fiohert Lafferty claims was the cause
of his injury. I always run the machine in the room over
the cane track that hr. Lafferty would take his mine car in
and out of the room. I rehenber the Ioet and the josition
of the goat which Ir. Lafferty claims caused his injury.

In running hy machine into this room, I always walked at
the side of the machine and always gassed between the
rachine and the yoet which Mr. Lafferty clains caused his
injury and my recollection is that this post stood erect

m¢%~wjl at a distance of about 2: feet from the track over which
would Ease my nachine and also any nine cars taken in or
cut of the room by hr. Robert Lafferty..

I cannot say whether the feet was loose or
not, as I do not remember of ever having cone in contact .
with it.

 . May 7th, 1915.
STATEHEET OF hAEVE HUNLEY
I was working in the nain entry close to
the room where hr. Robert Lefferty worked for The Cliff Coal
Co., and ugon one occasion Mr. Lefferty requested me to
assist him in gutting back ugon the track an enpty mine car
which wee off the track in his room and which had been derail— '
ed by hitting the zest and jarring it off the track. I would
estimate the dietence between the poet and the track in
Room No. l on the 6th left entry in the Cliff mine, which was
the room where hr. Robert Lafferty worled at about lfi feet.
I would estimate the distance between where the goet stood
and the track in 6th left entry at 15 feet to 20 feet. When
I assisted hr. Lefferty to rejlace the enlty nine oer Lenticne
ed above, I asked hr. Lafierty why he did not knock this
' garticular lost down, and he said that he had no axe to do
‘ so. I said to him that the tinber wee Unnecessary there,
as I sounded the to; and it we; gerfectly safe and the Ire} 1
unnecessary. I told him that it would ceuie hir trouble
in Iutting on Cars that it night derail. The room was u:
grade for a distance of 15 to 18 feet for a loaded car ’
coming out of room No. l on the 6th left to the main track
in 6th left.

 THE CLIFF COAL COMPANY
—M.NERs AND SHIPPERS——
CLIFFfl—fflo-WY. MILLERS CREEK DISTRICT KY. BLOCK _
05:“. —ea~anAL oFFICEs— v.. 231%? ...
PORTSMOUTH,OHKD ———
August 14, 1916.
Messrs. Harkins & Harkins, Attys—at-law, I
Prestonsburg, Ky.

Gentlemen:

we have your letter of the 9th inst. regarding the
Robert Lafferty case. we are enclosing our voucher No. 1161 for ‘
$212.50, in settlement as shown in the voucher, including your
fee for $50.00 in the case. This, we believe, will settle the
matter, with the exception of costs. We would kindly ask that '
you advise the amount of cost, and we will mail you voucher in
settlement of same. :

We would also ask that final disposition of this suit
be made when the case is called, so thai the court records will
Show that it is settled, and oblige, ‘ _

Yours truly, ‘
THE CLIFF COAL COMPANY.

BFV:P H