The Bridgeport evening farmer., 1912-12-31

then and there attempted to leave the said ear so burning as aforesaid and to escape therefrom, was by reason and in consequence of the said gross and culpable negligence of the said Henry J. Horn, Benjamin R. Pollock and Clayton N. Woodward as SaBch officers of said railroad company, then and there unable to leave and to es- cape from the said car so burning as aforesaid and prevented from 1eav- ing the same and from escaping there from, and by reason and in conse- quence of the said gross and culpable negligence of them the said Henry J. N. Woodward as such officers of said Railroad company was then and there unlawfully kept and confined within said car so burning as aforesaid, in consequence whereof and by reason of said gross and culpable negligence of said Henry J. Horn, Benjamin R. Po1- lock and Clayton N. Woodward as such officers of said railroad company, the said fire in the said car did then and there suffocate and set fire to and burn her the said Jane Doe.
 of the smoke thereof, she the said Jane Doe then and there had and received, and they the said Henry J. Horn, Benjamin R. Pollock and Clay said railroad company, with force and arms, feloniously and wilfuIly and with and by such gross and culpable negligence as aforesaid, did then and there give and cause to be given. to her the said Jane Doe, certain nor tai choking and suffocation, and by means of the said fire and the flames thereof. she, the said Jane Doe then and there had and received, and that they the said Henry J. Horn, Ben ja min R. Pollock and Clayton N. Railroad company, with force and arms, wilfu11y and feloniously and negligence as aforesaid, did then and there give and cause to be given to her, the said Jane Doe. certain divers mortal wounds, sores and burns, a to said Attorney unknown, in and up- on the head. body and limbs of her, the said Jane Doe, of which said nor tai choking and suffocation and of said mortal burns. sores and wounds she. the said Jane Doe, did then and there instantly die; and so the Att said Henry J. Horn. Benjamin R. Pol lock and Clayton N. Woodward, as such officers of said Railroad conn pany, her the said Jane Doe. in the manner and by the means aforesaid, by
 their gross and culpab1e negligence aforesaid, wi1fully and feloniously did kill and s1ay, and did thereby then and there commit the crime of man slaughter, against the peace and con- trary to the statate in such case made
 '4th Count: And said attorney for the State further complaint and i'm formation makes that on said 3rd day of October, 1912, the said Henry J. Horn, Benjamin R. Pollock and Clay ton N. Woodward were then the Vice President, General Superintendent and Superintendent of the Shore Line Di- vision of said the New York New Ha- ven & Hartford Railroad Company, respectively, Gin which said division said town of Westport is situated) which said railroad company was then and there operating certain trains up- it's tracks through said town of Westport, and the said Henry J. Horn, Benjamin R. Pollock and Clay ton N. Woodward, as such officers of said railroad com pany, then and there tracks of said railroad company, did then and there have and exercise su- perviSion and. control of the same and should have used and exercised every care and precautfon in their power