CLAIM OF JAMES A. HUGHES (LUCIAN P. SMITH)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK.
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In the Matter
-of the-
Petition of the Oceanic Steam Navigation
Company, Ltd., Owner of the Steamship
"Titanic", for Limitation of Liability, etc.
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CLAIM OF JAMES A. HUGHES AS ADMINISTRATOR OF
THE ESTATE OF LUCIAN P. SMITH, DECEASED.
Now comes James A. Hughes, Administrator of the Estate of Lucian P. Smith, deceased, and makes and files his claim as such Administrator in the sum of thirty three thousand four hundred and thirty-one and 40/100 dollars $33,431.40) and alleges as follows:
That he is a resident of Huntington in the State of West Virginia, and was on the 12th day of November, 1912, duly appointed Administrator of the Estate of Lucian P. Smith, deceased, by the County Court of Cabell County, State of West Virginia .
And claimant further alleges that his decedent, Lucian P. Smith, was on or about the 15th day of April, 1912, a passenger on board the Steamship "Titanic" belonging to the petitioner herein, which vessel on that day sank in the waters of the Atlantic Ocean, as set forth in the petition herein, and by such sinking, claimant's decedent lost his life to the damage of this claimant in the sum of twenty five thousand dollars ($25,000.00).
And claimant further alleges that, at the time of the sinking of the said Steamship "Titanic", the said Lucian P. Smith, claimant's decedent, had with him personal property of the value of eight thousand four hundred and thirty one and 40/100 dollars ($8431.40), a true and itemized statement whereof and of the reasonable value whereof is hereto annexed, marked Schedule A, which property became wholly lost by reason of the sinking of the said Steamship, and claimant has been thereby damaged in the additional sum of eight thousand four hundred and thirty one and 40/100 dollars ($8,431.40).
And claimant further alleges, upon information and belief, that the said sinking of the said Steamship "Titanic" was caused by negligence on the part of the petitioner herein, its officers and agents, and was occasioned by and with the privity and knowledge of the petitioner itself.
And claimant further alleges that the Steamship "Titanic" was an English vessel, and that, by and under the laws of Great Britain, whensoever the death of a person is caused by wrongful act, neglect or default and the act, neglect or default is such as would, if death had not ensued, have entitled the party injured to maintain an action and recover damages in respect thereof, then and in every such case the person who would have been liable if death had not ensued, shall be liable to an action for damages, notwithstanding the death of the person injured.
And claimant further alleges that no credits have been given and no payments have been made on account of his said claim.
J. A. Hughes (sig.)
Claimant,
Administrator
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UNITED STATES OF AMERICA , )
Southern DISTRICT OF VIRGINIA, ) SS.:
COUNTY OF Cabell Co. )
JAMES A. HUGHES, being duly sworn, deposes and says, that he is the Administrator of the Estate above-named and the claimant herein; that he has read the foregoing claim and knows the contents thereof; that the same is true of 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.
| Sworn to before me this | J. A. HUGHES (sig.) |
| 31st day of Dec 1912. |
E. A. JORDAN (sig.)
Notary Public.
Commission expires
Oct 26, 1916.