CLAIM OF MARGARET BROWN
UNITED STATES DISTRICT COURT
E. POWIS JONES |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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IN THE MATTER |
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To ALEXANDER GILCITRIST, JR., Commissioner appointed to receive claims herein, the claim of MARGARET BROWN, alleges, upon information and belief:
I.
That she is a citizen of the United States and a citizen and resident of the State of Colorado at present sojourning in the Empire of Germany.
II.
That the above named petitioner is and at all times hereinafter mentioned
was a corporation organized and existing under the Laws of the United Kingdom of Great Britain and Ireland and an English registered company and carrier, and the owner of the steamship "TITANIC".
At the time hereinafter mentioned said steamship "TITANIC" was a British seagoing ship, and upon information and belief had been duly registered pursuant to the Laws of the United Kingdom of Great Britain and Ireland and hailed from the port of Liverpool in said Kingdom, was one of a line of cargo and passenger steamships operated by petitioner between Southampton and New York.
III.
That on or about April 10th, 1912 this claimant took passage at Southampton, England, on said steamship “TITANIC” under a contract previously made between this claimant and the petitioner herein for a valuable consideration paid to petitioner by the terms of which contract, petitioner agreed safely to transport this claimant as a passenger, together with her luggage and personal effects from Southampton to New York.
IV.
That while on said voyage and on the high seas in or near Latitude 41 d. 46 m. N. Longitude 50 d. 14 m. W. said steamship “TITAITIC” collided with an iceberg on April 14th 1912 and shortly afterward sank, causing the death of a large number of persons and the loss of the cargo, baggage and personal effects contained in said vessel. That such loss of the steamship TITANIC” and the lives and property of persons on board thereof were caused by the wrongful acts, fault and negligence of petitioner, Oceanic Steam Navigation Company, Limited, and of petitioners agents and servants in the navigation of said vessel and in failing to make said vessel seaworthy and properly manned, equipped and supplied, and otherwise, and such loss and destruction of lives and property was with the privity, fault and knowledge of the petitioner, and occurred without fault on the part of this claimant.
V.
That included in the property so lost and destroyod as aforesaid were certain luggage and personal effects, the property of this claimant, which petitioner had contracted safely to transport from Southampton to Now York. Said property was never saved or recovered and an itemized list thereof with the market values of each item at the date of such loss, is hereto annexed marked “SCHEDULE A” and made a part hereof. No credits have been given thereon and no payments have been made on account thereof.
VI.
That by reason of the premises the claimant has been damaged in the sum of fourteen thousand six hundred and twenty-three ($14,623.00) dollars.
WHEREFORE claimant hereby makes and files her claim against the above named petitioner, Oceanic Steam Navigation Company, Ltd. for the sum of $14,623 and prays that the Commissioner appointed to receive claims herein will report to the Court that said sum is due to this claimant and should be allowed to her out of any funds deposited in the Registry of this Court in this proceeding and that this Court decree that this claimant recover from the petitioner her damages as aforesaid with interest and costs and for such other and further relief as may be just.
E. Powis Jones(sig.)
Proctor for claimant.
Office & Post office address
40 Wall Street
Borough of Manhattan
The City of New York