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, Sept., 17th., 1917.
Mr. S. M. Wilson,
Counsel,
‘ Lexington, Ky.,
Dear Sir:-
I have your letter of the 14th inst, relative
to case of Sambo Couch v L&N RR. 00., Perry Circuit Court.
This matter is now in the hands of Mr. Landrum,
undergoing investigation. He says he will be able to report
on this case in the next few days.
Yours truly,
j ' 4'. 'P2‘/2’/ Z // /, K . ’1
Asstt. District Attorney;‘w
AMW/ s . ‘ '
cc.
I‘JII'O' C o S o 11de ,
'Law Agent, Ravenna, Ky.,

 . i
’ Septewber 14, 1917,
Hr. J. J. Donohuey ,
Asst. Dist. Atty., 3&N BL 00.,
Louisville, Kentucky.
Bear Sir:
Barbe Couch v. 3&3 RE Co.~ Perry Circuit Court.
Please let me have investigation papers relative to the
ahcve case as nromptly as possible. {organ & Huckcls are aflaing
for renort in order that they may prepare Answer. -
?mumitmfly,
:"-_ '
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PERRY CIRCUIT COURT.
Sambo Couch Plaintiff
vs. - PETITION
Louisville & Nashville
Reiered Company Defendant.

The plaintiff stntes that the defendant, Louisville
and Nashville Railroad Co., is a corporation, crested, organ-
ized and existing under and by virtue of the laws of the state of
Kentucky and as such has a right to sue and to be sued, contract
and be contnicted with and has for its business onireting a line
of railroad and is a common carrier.

The plaintiff states, that he was at the time the
wrongs hereinafter complained of were committed and at all times
since said date and now is a citizen and resident of Berry County,
Kentucky.

The plaintiff, Sembo Couch, states that the defendant,
the Louisville a hashville Raiered Company, on the 2nd day of
June, 1917, and for more than one year prior thereto and at all
times since eeid date Operated a line of raiernd with tn1ins and
cars thereon from Lexington, Kentucky, to ficRohert, Kentucky,
passing through and in Ferny County, Kentucky, and that its said
line of railroad was on snid dates and during slid mlne Operated
between Yerkes, Berry County, Kaitucky, and Hazard, Ferry County,

. Kentucky, such of which places were stations on said road at

' which it received passengers and permitted them to get off of its
passenger train on its said road, and that it Operated its said
road as a common carrier for RLSSGHSGTS for hhfe; that Hazard is
and was a station on said read at which it sold tickets to uls—
sengers and rerkes is a station on said road at which it did not
sell tickets for passengers but that after it had received nss- '
sengers at said station its conductors on its trains collected
from its passengers, the hire or fare.

 .\, . .
' Plaintiff states that on the 2nd day of June 1917, he
. took passage on plaintiff‘s passenger train at Yerkes station on
its said line of railroad and on its passenger train which de-
parted from said station going to Hazard, Kentucky, shortly after
12 o'clock, noon, on said day. He states that soon after it re-
ceived him as a passenger on its said train at said station its
conductor on said train and in charge of said train collected
from him the hire or fare entitling him to ride as a passenger on
its seid fizssenger train from ierkes to Hazard, Kentucky and paid
its Said conductor the fare charged by it for passage on ed.d train
from said Yerkes station to hazard, Kentucky, which entitled him
plaintiff to be carried as a passenger on defendant’s passenger
train which left ferkes, Kentucky, shortly afternoon on said day,
to Hazard, hentucky, end that the amount paid its said conductor
was the usual price charged passengers for passage from Yerkes,
Kentucky to hazard, Kentucky, by defendant. He states that after
said train had left Ierkes, Kentucky, in Berry County, Kenuicky,
and on its way to Hazard, Kentucky, on that date end at a point
about three quarters of a mile distance from the depot at Hazard,
Kentucky, and ct a point at or near defendant's Gosling station
near the corporate limits of the city of hazard and after plain-
tiff had paid for his fare m7 passage to defendant's conductor,
as aforesaid, and before said train had reached the station at 3
Hazard, Kentucky, where it received and allaved uissengers end
before it had reached the point at which was the destination to
V which plaintiff was entitled to ride on said train, defendant's
conductor in a boisterous, rude and insulting, high-handed and
oppressive manner, demanded of fiiis plaintiff his ticket, or
his far, from thet point to the depot or station at Hazard,
Kentucky, notwithstanding the feet that plaintiff had already
paid the defendant's conductor his fare entitling him to ride
from lurkes, Kentucky to Hazard, Kentucky, rlsintiff then in-

 formed defendant’s conductor that he had already paid him his
fare entitling him to be carried to Hazard, Kentucky, and when
plaintiff hud thus informed Said conductor thereupon refused to
permit the plaintiff to ride further and in a very rude, in-
sulting, rough and boisterous manner ejected this plaintiff
from said pieSengcr train and refueed to permit him to ride upon
eeid train to his deetiuction, end rudely, roughly and ineultingly
ordered him to leave said train and refueed to permit him to ride
thereon and rudely, roughly and ineultingly pushed or ehoved him
from enid truin to the ground, whereby plaintiff wee caused to
walk from the piece Where he Was ejected from said train, some
finneexuuerexe three-fourths of a mile to Eueard, Kentucky, all
to plaintiff’s damage in the sum of ($5000.00) Boilers.
WISREEJRE, :leintiff gray; judgnent against the de—
fendant, Louieville u Lashville Ruierud Company for the eum of
three thouednd dollere, (f5000.00), for his costs and all proper
relief.
E.J. Evereole a flour d Johnson
Ehe effiunt, Jembo Cauch, state: thut the eteteMents
contained in the rorcjoing yQtitiOfl are true as he verily be-
lieves.
_u____.__m__~__l.~_____.__._______
Subscribed and eworn to before me by Sdmbo Couch, this
the day or , 1917 .
__..."__.___________.______—_—————