Evening capital. (Annapolis, Md.) 1884-1910, 1903-07-17
Filed In The Circuit Court To-
day-Argument Set For
Hearing On Next
Thursday.


E. Martin, Emma B. Feldmeyer, Lulu
o. Merrill and Katherine Emory. called
respectively Mrs. Anna L. Cresap, Mrs.
John w. Martin. Mrs. George T. Field
meyer. Mrs. George +. Merrill and Miss
Kate Emory. in the bill Of complaint in
the above entitled case against them in
this Court exhibited, respectfully shows:
"Ist. They deny the allegations OF the
first paragraph OF the said petition as
therein set forth.
(That they (the Board OF Managers) have inter.
fered in every possible way with the Medical
Statf and the superintendent OF said Hospital by
ref sing admission 20 all persons having business
there and by refusing and attempting 10 prevent
the entrance 10 said Hospital OF the attorney OF
the Medical stan, the superintendent and the said
Mrs. Isabella j. Thomasl
"7nd. They deny the allegations Of
the second paragraph of the said peti-
ton as therein set forth.
THAT the said superintendent, Miss Pusey, and
Mrs. Thomas, were unable, up 20 the time OF
nling this petition, TO give the patient, Agnes
prepared the same and the defendants having
promptly converted 1t to their own use.9
"3rd. They deny the alleg ations of
the third paragraph of the said petition
as therein set forth.
THAT the life OF the patient, Agnes Thomas, was
endangered by the condHct OF the defendants, and
the work OF the Medical STAFF and the superiu-
tendent thereby seriously interfered with.)
Further answering the said petition the
respondents show
18th. That these defendants, together
with Emma Abbott-Gage, Anna B. Steele
and Katherine Andrews, are the duly
elected and constituted Board of Man
ayers OF the Annapolis Emergency Hos
pital Association, corporation duly In
corporated under the general laws Of the
State, to whom by the charter of said
corporation and by the constitution
thereof, duly adopted. Ia copy whereof
has been fled with the petition in this
case as an exhibit) has been delegated
the charge and control OF the Emergency
Hospital tAnnapolis. That acting nndet
the general authority contained In said
charter and constitution and bylaws and
particularly in conformity with bylaw
No. 7. entitled Superintendent. which
declares that "the Board of Managers
shall appoint a trained nurse as the
superintendent of the Hospital upon the
recommendation of the Executive Com
mittee OF the Medical Staff at such salary
as the Board shah fix," the Board OF
Managers, upon the recommendation OF
the Medical Staff OF the Hospital on the
I4.h day OF July. 1902. appointed Miss
Nellie M. Pusey, trained nurse, as the
superintendent OF the Hospital for the
period of one year al a salary of six
hundred dollars (s6oo) per year. payable
monthly, and that the said Nellie M
Pusey accepted said Office upon said
terms and took charge Of said hospital as
superintendent on the I4th day OF July,
1902. subject to all the conditions i'm
posed by said constitution and bylaws.
"5th. That the said Nellie M. Pusey is
no longer the Superintendent of said
hospital. her term OF employment there
having ended on the I4th day Of July.
1903, pursuant to written notice sent to
her by the Managers OF said hospital on
the and day of April. 1903. copy OF which
notice is herewith filed marked Defen-
dants' Exhibit A. That said Nellie NJ
Pusey hath no rights, powers or duties
at said hospital and that her continued
presence there after the expiration Of her
term Of employment and after the said
notice to her from the trustees of the
hospital, is in defiance of their authority
and that she Is trespasser upon their
property.
10th. That the Board of Managers
eating under its powers as contsined in
the constitution OF said Association ad-
dressed letters to the Executive Com
mitiee of the Hospital Staff. daied June
~ and 27th, copies OF which letters are
herewith filed marked Exhibit b, asking
said Staff TO recommend to the Board of
Managers a trained nurse as Supi. to
succeed Miss Pusey, but that the said
Executive Committee Of the Staff re-
fused to make any recommendation or
10 meet said Board Of Managers for that
purpose. and on the 9th day of July,
1905. addressed = communication to said
Board Ia copy Of which Is herewith fled
marked Exhibit C) denying the Boards
rights to remove Miss Pusey and their
unwillingness to make any appointment;
and acting under its general powers the
Board Of Managers by resolution at a
Special meeting held on the nth day OF
July, 1903 Ia copy whereof is herewith
filed marked Exhibit D) appointed Miss
Katherine Emory a graduate nurse OF
the Johns Hopkins School of Nurses in
the Class of 1891, who was possessed OF
the highest qualifications and came with
the highest testimonials from ply sicians
in Baltimore and from some OF the non
resident members Of the Medical Staff OF
said hospital, as nurse in charge Of the
said hospital from the 9Th day of July,
1903. until Superintendent should BE-
appointed by the Board Of Managers
upon Recommendation of the Executive
Committee of the Medical Staff of the
Hospital; and that notices were sent to
the members of the Hospital Staff In
forming them Of Miss Emory's appoint
ment to take charge Of the internal
affairs Of the hospital from the date afoTe-
said; and that on the evening Of July
I4ih. 1893, the Executive Committee oi
the BoaFu Of Managers met Miss Pusey
at the hospitsl, informed her Of her sue
cessOr coming the following day. and
paid her the salary due 10 the 18Th Of
July. 1908. That upon the morning Of