The Jersey City news. (Jersey City [N.J.]) 1889-1906, 1900-06-30
RIDICULOUS VERDIAGE
Unnecessary Language il
Which a Legal Summons
Is Expressed.

A summons in a suit for damages in
stituted by Miss Isabella Jarvis of Bay
onne. against the New Jersey Central
Railroad is an Illustration of the legal
and, to the lay mind, unnecessary and
ridiculous verbiage used in such docu-
ments. The summons was prepared by
Jarvis N. Atkinson and Edward H. Hoos.
counsel for the plaintiff Miss Jarvis, who
sues for $1,000 through Alpha E. Jarvis,
her next friend, was injured at the
Thirty-third street station on February 1,
1899, while stepping from car. All that
happened to her was a wrenching of the
ankle by stepping on a stone, but the
summons describes it in this fashion,
THE said plaintiff, by James N. Atkin-
son and Edward H. Hoos, her attorneys,
complains for that, whereas, the said
defendant heretofore to wit on the first
day of February, 1899, at the time of COM
mitting the grievances hereinafter mem
toned, was possessor, operator and man
ager of a certain railroad of great length,
that is to say, the main trunk Of said
railroad in part extending from the city
Of Jersey City to Bayonne, New Jersey,
and from thence TO Elizabeth, N. J., and
from thence returning to said Bayonne,
N. j. On the first day of February, 1899,
at the city of Bayonne, at the Thirty
third street railroad station Of said de-
fendant, Isabella Jarvis, the plaintiff, be-
came and was a passenger of said defend
ant for certain hire and reward to wit:
the sum of fifty cents in that behalf ex-
tended by said plaintiff and accepted by
said defendant as full payment for said
fare to be safely and securely carried and
conveyed on certain journey from Eliza
beth, New Jersey, to the city
of Bayonne, New Jersey, to
wit: to said station known
and designated as the Thirty-third sta
ton; and that said plaintiff was carried
by said defendant in due course to afore-
said station, and while said train of said
defendant, on which said plaintiff was a
passenger, was at stop at said Thirty
third street station, in the City of Bay
onne, New Jersey. for the purpose of re-
ceiving and discharging passengers, said
plaintiff, while upon the platform of a
certain car of said defendant, was invited
| by a servant of said defendant by way of
the steps on the north side of said car,
and then and there it became the duty Of
said defendant to provide steps sufficient
4
tiff to alight from said steps of said car
| with safety to the ground, and then and
there it became the duty of the said de-
| fendant to keep the station grounds so
| that the said plaintiff could alight from
| said car in safety to said station grounds;
but said defendant, not regarding its
duty, by its servants so negligently con-
| structed the steps of said car that the
| lowest step of said car was at great dis
| lance from said station grounds, so at
| said defendant could not alight
with safety from said car and 50
negligently, by It's servants, maintained
| its said station grounds that said plaintiff
could not step from said car to said sta
| ton grounds with safety, in that said de-
| fendant allowed a wide space, filled in
with small sharp stones to intervene be-
tween the northerly rail of said east
| bound tracks and its station platform at
| the point where said plaintiff was invited
| to alight, so that said plaintiff in allghting
| from said car of said defendant by inyi-
| tation and with the assistance of a SER
want of said company, stepped from the
| stems of said car upon said small sharp
| stone and was greatly hurt, cut, bruised
| and wounded, and became and was sick,
| sore, lame and disordered, and her right
! ankle was sprained and her right leg rem
dered useless for long space of time and
| will always continue weak and impaired,
/ and during all of which time the said
plaintiff suffered and endured great pain,
| and in the future will suffer and endure
great pain
The summons, which is made returnable
| on July 9, was served on the defendant
| TODAY by Constable Budden.