TIP | Limitation of Liability Hearings | Deposition of Elizabeth L. Lines

Limitation of Liability Hearings

DEPOSITION OF ELIZABETH L. LINES


DEPOSITION of Mrs. Elizabeth L. Lines, taken upon oral interrogatories, pursuant to Commission granted October 27, 1913, at the American Consulate-General, 36 Avenue de l'Opera, at the City of Paris, Republic of France, on the twenty-second day of November, One thousand nine hundred and thirteen.

Present:

Honorable FRANK H. MASON, Consul-General of the United States, Commissioner.
FREDERICK M. Brown, Esq., of counsel for Claimants;
HENRY EDWARD DUKE, Esq., and VIVIAN D. HEYNE, Esq., of counsel for Petitioner.

Mr. Brown:
The regularity of the notices and of the adjournments is admitted.

Mr. Duke:
You may take that to be so.

Mrs. Elizabeth L. Lines, being duly and publicly sworn pursuant to the directions hereto annexed, and examined on the part of the claimants, doth depose and say as follows:

DIRECT EXAMINATION BY MR. BROWN:

1. Mrs. Lines, please state your residence.
- One hundred and eleven Quai d'Orsay, Paris.

2. You are a citizen of what country?
- Of the United States

3. Were you a passenger on the Titanic upon her fatal voyage?
- I was.

4. With whom were you traveling at that time?
- With my daughter who was seventeen.

5. At what port did you embark?
- Cherbourg.

6. what was the location of your cabin?
- It was an outside stateroom amidship, on D deck.

7. What was the location of the dining saloon?
- On the same deck, further aft.

8. At the time of the fatal voyage of the Titanic, did you know by sight or were you acquainted with Mr. Bruce Ismay?
- Knew him by sight, I did not know him personally.

9. For how long did you know him by sight?
- Mr. Ismay lived in New York a number of years ago, and I had seen him there.

10. Then I gather that for some years you had known him by sight?
- My home was in New York City until thirteen years ago. I had seen Mr. Bruce Ismay during his residence in New York prior to that, twenty years ago. I recognized him when he came on the steamer and I asked my table steward if that were not Mr. Bruce Ismay, and he told me yes it was.

11. At the time of this voyage, did you know by sight or were you acquainted with Captain Smith, master of the Titanic?
- I had never seen Captain Smith.

12. Did you get to know him by sight on this voyage?
- He occupied the head table in the dining saloon, and I supposed he was Captain Smith. I asked my table steward if that were not Captain Smith and was told he was.

13. As you sat in the dining saloon, were you able to see Mr. Ismay and Captain Smith at their table?
- Not unless I turned my head, as they were behind me.

14. Do you know where they sat?
- Yes.

15. About how far from where you sat was their table in the dining saloon?
- The captain's table was at the top of the saloon.

16. About what distance do you think separated your table from the Captain's table?
- Two tables.

17. During that voyage, did you at any time hear a conversation or conversations between Mr. Ismay and Captain Smith?
- I heard a conversation on Saturday afternoon, the thirteenth of April.

18. Had you heard conversations between them before that time, or not?
- No; I heard them discussing ships the day before for a few moments in the lounge, but I had not paid any attention to it as I was passing through.

19. And I gather than on Friday, the day before, you did not hear the substance of their conversation.
- I could not hear the substance of their conversation.

20. Where was it that they were conversing on the Friday?
- In the corner of the lounge furthest from the dining room.

21. Won't you state where the lounge was situated?
- On the same deck. The lounge and the dining room were on the same deck, and my own state room was on the same deck. The lounge was between the dining room and the state rooms.

22. Was there any other room or space intervening between the dining saloon and the room that you have referred to as the lounge?
- No. There were doors between the two.

23. Will you look at this diagram and say whether or not the room which you describe as the lounge is the room marked on the diagram "First Class Reception Room"?
- Yes. It is the room immediately following the dining saloon. Here was my table in the dining saloon and here was the Captain's table. (Witness indicates as her table the third table from the bow in a tier of tables running from the starboard corner of one boiler casing to the starboard corner of the next boiler casing, and the witness indicates as the Captain's table the table in the medium longitudinal axis of the ship furthest forward of the five tables in that line.)

24. Mrs. Lines, you indicated a moment ago where the table was in what you call the lounge, at which the Captain and Mr. Ismay were sitting during the conversation on Friday. I think the stenographer did not take it down: will you please indicate that again?
- This is where they were sitting. (Witness indicates a table in the forward port corner of the room marked on the plan as "First Class Reception Room").

25. Mrs. Lines, you have already stated that on the following day, Saturday, you heard some conversation between Mr. Ismay and Captain Smith: please state where that conversation occurred?
- It was in that same lounge, as they called it, sitting-room, in the same corner that I have indicated.

26. Were they sitting at the same table that they occupied on the Friday?
- The same table.

27. Where were you at the time you heard this conversation?
- In the lounge, at a table very near.

28. When you use the word "lounge" do you mean in each case the room marked as "First Class Reception Room" on this plan?
- Yes.

29. Will you indicate the table at which you were sitting at the time you heard this conversation?
- I was sitting next to the outer side of the ship. (Witness indicates that the table at which she was sitting was the table next to the one used by the Captain and Mr. Ismay on the port side, but that there was a table further from the port side of the ship and somewhat between the table of the Captain and her own table).

30. Was this other table that you say was in a general way between yourself and the table and settee used by Mr. Ismay and the Captain in a direct line between you and Mr. Ismay's table?
- No.

31. How far out of a direct line would you say it would be?
- It was about four or five or six feet.

32. Did that other table stand in such a position as in any way to interfere with your view of Captain Smith and Mr. Ismay?
- No.

33. During the time that this conversation that you have referred to occurred, was there any person sitting in a position to interfere with your view?
- No.

34. Were there chairs in a direct line between you and Mr. Ismay and Captain Smith?
- Not that I recollect.

35. Would you be good enough to state when it was on Saturday April thirteenth that this conversation occurred?
- After the midday meal I went into the lounge to have my coffee - in the general reception room.

36. Were the Captain and Mr. Ismay already there?
- No, they came in after I was seated, and went to this same table which I had seen them occupy on the Friday.

37. Could you estimate about what time it was that the Captain and Mr. Ismay entered the reception room or lounge?
- Perhaps half past one.

38. Do you recall what your luncheon hour was?
- No, because it varied; it was a little later some days and a little earlier other days; but I should say that it was about one thirty when I went into the lounge.

39. About how long, within your knowledge, did Mr. Ismay and Captain Smith remain in this reception room engaged in conversation?
- At least two hours.

40. Were you there all of that time?
- I was there.

41. Are you able to state from your recollection the words that you heard spoken between Mr. Ismay and Captain Smith on that occasion?
- We had had a very good run. At first I did not pay any attention to what they were saying, they were simply talking and I was occupied, and then my attention was arrested by hearing the day's run discussed, which I already knew had been a very good one in the preceeding (sic) twenty-four hours, and I heard Mr. Ismay - it was Mr. Ismay who did the talking - I heard him give the length of the run, and I heard him say "Well, we did better to-day than we did yesterday, we made a better run to-day than we did yesterday, we will make a better run to-morrow. Things are working smoothly, the machinery is bearing the test, the boilers are working well". They went on discussing it, and then I heard him make the statement: "We will beat the Olympic and get in to New York on Tuesday."

42. In your last statement, Mrs. Lines, were you giving the substance of the conversation or the exact words which were used?
- I heard "We will beat the Olympic and get in to New York on Tuesday" in those words.

43. If there were any particular words spoken that you can remember, I should be glad to hear them.
- Those words fixed themselves in my mind: "We will beat the Olympic and get in to New York on Tuesday."

44. Do I understand you to say that the other things that you stated were the general substance of what you heard and not the exact things or words used?
- No, I heard those statements.

45. What was said by Mr. Ismay as regards the condition of the performances, of the engines, machinery and boilers?
- He said they were doing well, they were bearing the extra pressure. The first day's run had been less, the second day's run had been a little greater. He said "You see they are standing the pressure, everything is going well, the boilers are working well, we can do better to-morrow, we will make a better run to-morrow."

46. In speaking of standing the pressure well, Mr. Ismay was referring to the boilers, was he not?
- Of the boilers, I gathered.

47. I understand that hitherto you have been stating what you heard Mr. Ismay say: is that true?
- Yes.

48. What, if anything, did you hear Captain Smith say?
- I did not hear anything.

49. Did you hear the sound of his voice?
- No.

50. Won't you describe as well as you can, the tone and gesture of Mr. Ismay in this conversation?
- It was very positive, one might almost say dictatorial. He asked no questions.

51. Mrs. Lines, if you can recall anything else sat at that conversation, either in words or in substance, please state it.
- There was a great deal of repetition. I heard them discuss other steamers, but what I paid the most attention to was the Titanic's runs, and it was simply that Mr. Ismay repeated several times "Captain, we have done so and so, we have done so and so, everything is working well." He seemed to dwell upon the fact, and it took quite a little time, and then finally I heard this very positive assertion: "We will beat the Olympic and we will get into New York on Tuesday" but he asked no questions.

52. Did you hear anything said by Mr. Ismay that directly or indirectly sought information from Captain Smith as to the performances of the vessel or as to Captain Smith's opinion of what the vessel could fairly do?
- No, I did not.

53. What would you say as to your ability to hear all that was said in an ordinary tone of voice between Captain Smith and Mr. Ismay in the positions in which they were and you were on that afternoon of Saturday?
- It was quite possible, as during the latter part of the time there were very few people left in the lounge and it was quiet.

54. You say it was possible for you to hear?
- It was possible to hear ordinary conversation.

55. Do you recall any conversation on that occasion between Mr. Ismay and Captain Smith as to the performances of another vessel of the line?
- No, excepting the comparison with the runs of the Olympic.

56. And what runs of the Olympic were they using as a comparison?
- The trial trip.

57. Do you mean the maiden voyage?
- Yes, the maiden voyage.

58. And what was the substance or the words if you can give them, of the conversation as regards the Olympic?
- It was comparison, and that the Titanic was doing equally well, and they seemed to think a little more pressure could be put on the boilers and the speed increased so that the maiden trip of the Titanic would exceed the maiden trip of the Olympic in speed.

59. Mrs. Lines, won't you explain just what you mean by your words "They seemed to think"? I wish to exclude your own impressions and ask you merely what you heard said on that subject?
- They stated the run of the Titanic was equal to the run of the Olympic. Mr. Ismay did the talking, I did not hear Captain Smith's voice. I saw him nod his head a few times.

60. Did he nod his head so as to indicate assent or dissent?
- Assent.

61What was it that Mr. Ismay said from which you say you drew the impression that they seemed to think that the Titanic would beat the Olympic or that the Titanic compared well with the Olympic?
- They made comparisons in numbers which I cannot repeat, the number of miles run in various days. Mr. Ismay gave the runs made on certain days by the Olympic on its maiden voyage and compared them with the runs made y the Titanic on the first days.

62. You have stated several times, Mrs. Lines, that Mr. Ismay made assertions or statements as to what "we" would do, using the pronoun "we". Did he use any other pronoun that you know of in this conversation?
- No, Mr. Ismay said "we" and he asked no questions. He made assertions, he made statements. I did not hear him defer to Captain Smith at all.

63. Was there any part of that conversation that indicated whether or not Captain Smith deferred to Mr. Ismay?

Mr. Duke:
Object on the ground that it is leading, a question as to the impression of the witness's mind, and that the impression of the witness's mind is irrelevant. Further object on the ground that it is cross-examination.

- No.

64. Did you leave the reception room or lounge where this conversation occurred before Mr. Ismay and Captain Smith or was it the reverse?
- They left the reception room.

65. What was the end of the conversation, as far as you can remember hearing it?
- "Come on, Captain, we will get somebody and go down to the squash courts."

66. That was whose remark?
- Mr. Ismay's.

67. Won't you tell me again, as correctly as you can recall it, what was said by Mr. Ismay or Captain Smith as to the intended or expected arrival of the Titanic in New York?

Mr. Duke:
Object on the ground that it is cross-examination: witness has answered three times.

- "We will beat the Olympic and get into New York on Tuesday".

68. Did you hear or feel the impact of ice with the titanic at the time of the fatal disaster?
- Yes, I heard

69. Where were you at the time?
- In bed.

70. You and your daughter were saved in one of the lifeboats?
- Yes.

71. What was the occasion of your going on deck and getting into the life boat?
- We heard a man shout to his son to run for the life boats.

72. Was it the voice of anybody you knew?
- The voice of a friend who had a state room close to us.

73. Was any warning given to you or to anyone else within your hearing by any officer or member of the crew of the Titanic that there was danger or that persons should go on deck and get into the life boats?
- (Witness shakes her head) I was told to stay in my state room.

74. Who told you that?
- The steward.

75. Was anything else told you with reference to this subject by any person in the employ of the White Star Line?
- No.

CROSS-EXAMINATION BY MR. DUKE:

76. How many stewards or stewardesses did you see in the course of the time between the collision and your going on deck to get into the boat?
- My own steward, no other.

77. Did you see him again after the time of which you have said that he told you to stay in your state room?
- I saw him just as I left the ship.

78. Did you receive assistance in getting into the life boat?
- Yes, there was a man on each side of me who took me by my arms and swung me into the boat.

79. It was the only assistance possible?
- It was the only assistance possible.

80. did I understand you to suggest that you were hindered in any way in your access to the life boats?
- No.

81. Could you remember at what time you went to the life boat?
- I should say between half past twelve and one o'clock, perhaps a quarter before one.

82. Do you remember at all what time it was your steward said to you you had better stay in your state room?
- Immediately after the ship struck, at a quarter before twelve, and I was told then to stay in my state room, that there was no danger.

83. Did you gather at that time it was thought and hoped that there was nothing serious the matter?
- I was told so.

84. How soon after that was it you found that there was reality of danger?
- More than half an hour.

85. Did I understand you to say that you then found that the occupant of a neighboring stateroom was going on deck to seek a life boat?
- No; I heard him call to his son to run for the life boats.

86. And thereupon did you get up and go on deck?
- At once.

87. On what day did you leave Cherbourg?
- Wednesday.

88. On what day did you recognize Mr. Bruce Ismay?
- Wednesday night.

89. Had you any conversation with him?
- No.

90. Can you tell me, by reference to the plan of the dining room, where Mr. Ismay sat at dinner and at lunch?
- On the Captain's right.

91. You mean that he sat at the Captain's table?
- At the Captain's table on the Captain's right hand.

92. That you are clear upon?
- Oh yes.

93. A gentleman who sat at the Captain's table on the Captain's right hand was the gentleman with whom, as you have told us, the Captain was engaged in conversation on the two occasions you have mentioned?
- Yes.

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