The Washington times., 1934-07-28
Statement insufficient

64d4A1Ik44 LII G1kG 11TSL CUu11O VI
his declaration, although alleging
generally a duty on the part Of
this defendant to use due care in
the operation and maintenance Of
its automobile and that "the de-
fendant corporation, acting
through its agent, servant and
employe. and the defendant, Ed
ward H. Eaton, so careleSSly and
negligently operated and main
tanned their respective motor We
hicleS, at the time and place afore-
said, as to cause the motor We
hicle of the defendant, Edward H.
Eaton, to collide with great force
and violence with the person Of
the plaintiff, whereby and by rea
son whereof, the person Of the
plaintiff was severely and per-
manently injured" wholly and
utterly fails and omits to set forth
any facts showing the specific
acts of negligence and careleSSness
on the part Of this defendant
through its servant, agent or EN-
ploye which were a breach of It's
duty aforesaid and which prUxf.
mately caused plaintiffs injury,
or that such acts Of negligence
and carelessness, If any, on the
part of defendants agent, servant
and employe were in any wise
casually connected with any al
legged acts of negligence Of the de-
fendant, Edward H. Eaton. so aS
to contribute to plaintiffs injury.
Plaintiff in the second count Of
his declaration, although alleging
the same general duty Of care on
this defendant as in the first
count and charging certain gen.
eral acts of negligence on the part
of the defendant corporation and
the defendant, Edward H. Eaton,
such as failing to keep their We
hicles under proper control, to
maintain a proper lookout and in
violating certain provisions of the
traffic regulations, wholly and ut
terly fails and omitS to set forth
any facts showing breach Of its
duty and the causal connection
between the alleged acts of negli-
gence by the defendant corpora
ton and the alleged acts Of negli-
gence by the defendant, Edward
H. Eaton, which caused the de-
fendant, Edward H. Eaton, to col
lide with plaintiff, as alleged.
Plaintiff in the third count Of
his declaration, although alleging
generally a duty on this defendant
to use due care and that 1.-The
defendant corporation, acting
through it's agent, servant and
employe, and the defendant, Ed
ward H. Eaton, so carelessly and
negligently operated and main
tanned their respective motor We
hicleS, at the time and place afore-
said, so as to cause the motor
vehicle of the defendant corpora
ton, acting through its agent,
servant and employe, to collide
with the automobile of the plain
tiff: whereby and by reason
whereof parts and appurtenances
connected with said automobile
were badly damaged" wholly and
utterly fails and omits to set
forth any facts showing the spe-
cific acts of negligence and care
lessness on the part Of this de-
fendant, acting through its serv-
ant, agent and employe, which
were the breach of its duty afore-
said and which proximately caused
the damage to plaintiffs auto
mobile or how the acts Of negli-
gence and carelessness, If any, on
the part of defendants servant,
agent and employe in any wise
concurred with the alleged acts of
negligence of the defendant, Ed
ward H. Eaton, so as to cause
the alleged property damage to
plaintiffs automobile.