CLAIM OF CARRIE T. CHAFFEE, WALTER REED AND ROBERT REED (HERBERT F. CHAFFEE)
UNITED STATES DISTRICT COURT,
SOUTHERN DISTRICT OF NEW YORK.
| ---------------------------------------------------------x In the Matter of the Petition Of The Oceanic Steam Navigation Company, Limited, owner of the Steamship TITANIC, in a cause of Limitation of Liability. ---------------------------------------------------------x |
Claim |
To Alexander Gilchrist, Jr., Esq., a Commissioner appointed to receive claims in the above entitled matter.
Carrie T. Chaffee, Walter R. Reed and Robert B. Reed, administrators of the Estate of Herbert Fuller Chaffee, deceased, allege upon information and belief as follows:
First. That claimants were, on the 31st day of July 1912, duly appointed administrators of the Estate of Herbert Fuller Chaffee, deceased, by the County Court of Cass County in the State of North Dakota, in which county and said state Herbert Fuller Chaffee; resided.
Second. That on or about April 15, 1912, said Herbert Fuller Chaffee, a citizen of the United States and resident of North Dakota, was a first class passenger on board the S/S Titanic at the time of the sinking of the said steamship described in the libel and petition herein; that by reason of the said sinking of the said steamship through the actual fault of the petitioner the Oceanic Steam Navigation Company, Limited, and through the fault of its servants and agents in. charge of the said steamship Titanic with the privity and knowledge of petitioner and without fault on his part, the said Herbert Fuller Chaffee was killed.
Third. That the said Herbert Fuller Chaffee, at the time of his death was forty-six years of age, and was the president and general manager of the following corporations, to wit; The Amenia & Sharon Land Company and the Miller-Chaffee-Reed Company, both farming grain and real estate companies; The John Miller Company, a grain commission company having its principal offices at Duluth and Minneapolis; Chaffee-Miller Milling Company, a corporation engaged in the manufacture of flour; and Amenia Elevator Company engaged in the operation of grain elevators; that said Chaffee was actively engaged in the management of other personal interests and managed for his wife, Carrie T. Chaffee, one of the claimants herein, her separate property; that the earning capacity of said Herbert Fuller Chaffee, had for several years past exceeded the sum of twenty-five thousand dollars ($25,000) per annum.
Fourth. That decedent left him surviving the claimant Carrie T. Chaffee, his widow, and his five children, Eben Whitney Chaffee, Dorothy Chaffee Stroud, Herbert Lawrence Chaffee, Florence Adele Chaffee and Lester Fuller Chaffee; and that all of said persons, excepting Dorothy Chaffee Stroud were dependent upon said decedent for their support.
Fifth. That under and by virtue of the statutes of England in such case made and provided claimants are entitled to maintain an action to recover damages for the death thus occasioned.
Sixth. That in the possession of said Herbert Fuller Chaffee, on board the said S/S Titanic at the time of the sinking thereof were clothing, jewelry, baggage and other personal property of the reasonable value of $1,000, which property was entirely lost and destroyed by reason of the said actual fault of the petitioner and by reason of the said fault of its servants and agents with the said privity and knowledge of the petitioner without any fault upon the part of the said decedent, and no part thereof has been recovered.
Seventh. That claimants have been damaged in the amount of two hundred and fifty thousand dollars ($250,000) by reason of the said death of the said decedent and in the amount of one thousand dollars ($1,000) by reason of the loss of said clothing, jewelry, baggage and other personal property.
WHEREFORE, claimants make claim for two hundred and fifty-one thousand dollars ($251,000) the amount of their damages herein, together with interest thereon from the 15th day of April 1912, no part of which has been paid.
Wallace, Butler & Brown (sig.)
Proctors for Claimants,
54 Wall Street,
New York City.
-----------------------------------------------------------
| Southern District of New York |
) : ss ) |
| City and County of New York |
Frederick M. Brown, being duly sworn, deposes and says that he is a member of the law firm of Wallace, Butler & Brown, proctors for the claimants above named; that he has read the foregoing claim and knows the contents thereof and that the same is true to his own knowledge, except as to the matters therein stated to be alleged upon information and belief and that as to those matters he believes it to be true. That the sources of deponent's information and the grounds of his belief are communications and letters received from claimants and from their attorney. That the reason why this verification is not made by one of the claimants herein is that all the said claimants reside outside the City of New York and the Southern District of New York and more than one hundred miles therefrom and that all of said claimants are absent from said city and said district.
Sworn to before me this )
16 th day of January 1913 )
Chas. Flynn (sig.)
NY. Co. NY. No. 51.