The news & observer. [volume] (Raleigh, N.C.) 1894-current, 1902-01-08
R. O. KING ASKS FOR
FORTY THOUSAND
Complaint Filed Yesterday in
Damage Suit.
IT is AGAINST R. & A. R. R.
Alleges that Tresrle and Track Were
1T is AGAINST R. & A. R. R.
Alleges that Tresrle and Track Were
Unsonnd and Unsafe.
ALLEGES THAT He IS UNFIT FOR WORK
The Document Gives the Grounds Upon Which
the Damage Suit viii be Brought in
the Courts. Says the Roadbed
Was Soft and Insecure.

Mr. r. o. King asks for $4,000 in his
suit for damages against the Seaboard
for injuries sustained in the wreck near
Cameron.
The complaint in the case was filed yes
terday afternoon with the clerk of the
court The action is brought against the
Raleigh and Augusta Air Line Railroad
one of the divisions comprising the Sea-
board
The complaint was prepared by Messrs.
Jones & Son, who represent the prose
cution. The document gives the grounds
for the suit. alleging that the wreck re-
suited from an unsound track, which
caused the rails to spread.
The complaint alleges that the Raleigh
and Augusta Air Line Railroad is a cor
Grafton duly existing under the laws OF
North Carolina.
That the plaintiff r. o. King purchased
q ticket at Hamlet over the said road on
or about Sept. 9th.
1lat while the engine of thu train on
which the plaintiff was a passenger was
running at a great rate IF speed about
an hour and a half behind it's schedule
time. on its way from Hamlet to Raleigh
near the town of Cameron. it became de-
rallied and there the plaintiff became per-
fGanently and seriously injured.
That said derailment and consequent
injury to plaintiff, were occasioned by
the negligence of the defendant, careless
ly and negligently permitting the track
and road bed at the place of derailment
to &c and remain in an unsafe and CAM
gerous condition. The complaint further
alleges that
"A trestle over a small stream at the
point of derailment, had become rotten
and out of repair. the cross ties upon
said trestle we're rotten and the timbers
supporting said cross ties were unsound
and unsafe. the rails were defective and
unsafe, the spikes were loose and unable
TO hold the rails to and upon the cross
ties. and the whole superstructure at that
point was in an unsound and unsafe con-
dition The road bed at that point and
where the cars left the track, on account
of the said derailment was unpacked
soft and insecure and not gravelled OIL
ballasted. The cross ties many of them
were rotten, so as to be unable to hold
Tue SPINS many VI Tue spiheS were HISS
ing, the ends of the cross ties mashed
and broken so as to render the said road
at that point unsafe and dangerous.
THAT as a result of this negligence
the said trestle, road bed and superstruc-
ture gave way, the track spread, the en-
CINE and cars were derailed some of the
cars telescoped and the plaintiff was ter
ribly and permanently injured. He was
confined to his bed for many weeks. in
Cured great expense for medical and
other attentions suffered and still suffers
great and intense mental and bodily
pain, suffered and now suffers excruciat-
ing mental anguish, loss of mental pow
err and was rendered physically unfit
entirely for, and incapable of perform
ing his work and following his vocation