Prince William County Virginia Clerk’s Loose Papers

case, where he was born and what he said about where he was born.

statements were untrue, and he gave his reasons why he made them.

Q. How many days did you work at Washington Steel and Ordnance place? Answer – five or six days.

Q. Do you know whether there were any x-ray photographs taken of your head? Answer – I think there were two photographs taken by Dr. Grover.

Q. Do you know the results of that x-ray picture?

RE-DIRECT EXAMINATION

Q. You said something about you gave up your position partly or wholly because you could not ride a wheel; how long had you been riding a wheel in your collection business and working for the Singer Sewing Machine Company? Answer – For the Singer Sewing Machine Company I rode it up to the time of the accident, and after that I had to walk.

Q. How long was it you had ridden it? Answer – Four or Five years.

Q. How many years did you ride a bicycle? Answer – In all about ten years.

of the railroads to show the relations between the two companies, but not to bear on negligence in any way.

the C&O Railway was operating over the line between Orange & Alexandria, Virginia, under a contract as specified in that lease.

wants to go in. I expect we had better object to its introduction, and then he can read what he chooses.

Richmond and Danville?

whole lease into the record, but we simply object to it.

Mackey has ask us to admit.

agreement dated December 23, 1890, between the Richmond and Danville Railroad Company, a corporation, and the Virginia Midland Railway Company, and the Chesapeake and Ohio Railway Company, paragraph second being as follows, found in Deed Book No. 40 at pages 338, 339, 340, 341, 242 of the Land Records of the county of Prince William, Virginia. The second paragraph is as follows:

defendants companies that the foregoing is all that need be offered in evidence of paragraph Two on behalf of the plaintiff, with the right on behalf of the defendants to read all or any other portion of said paragraph to the jury.

plaintiff, but that counsel for both defendant railways reserve the right to read to the jury all or any part of said paragraph three. We offer those in evidence with this limitation, that the court instruct the jury that the law fixes the degree ------

instructs the jury that the law fixes the care that a common carrier owes to the passenger as the utmost care, and the contract or lease between the Chesapeake and Ohio and Southern Railway was admitted in evidence for the purpose of showing the relative duties of those companies to each other, and for no other purpose, and that the effect of such contract or lease should be limited to that one question of the relative duties of the defendant companies to each other.” Now, we offer that in evidence.

The depositions of Dr. William T. Davis, taken pursuant to the annexed notice, at No. 927 17^th Street, Northwest, Washington, D.C. on Saturday, March 25^th, 1916, to be read as evidence in the above entitled cause.

Present:

Messrs. Crandal Mackey and Thomas H. Patterson, attorneys for plaintiff

Mr. Baumgardner, Claim Agent, Southern Railway Company

Mr. William H. Holloway, Notary Public.

The Stenographer and Witness

Thereupon: Dr. William T. Davis, a witness of lawful age, being duly sworn, testified as follows:

Q. State your name, age, residence and occupation? Answer – Dr. William T. Davis, age thirty nine; residence 927 17^th Street, Northwest, Washington, D. C.; occupation, physician.

Q. Doctor, where did you graduate in medicine? Answer – George Washington University; graduated in 1901.

Q. Are you a surgeon as well as a physician? Answer – Yes.

Q. Have you practiced medicine and surgery ever since your graduation? Answer – Yes, sir.

Q. What if any medical societies do you belong to? Answer – District of Columbia Medical Society, American Medical Association, College of American Surgeons.

Q. Do you make any specialty of any branch of your profession? Answer – Yes, ophthalmology.

Q. Doctor, explain what you mean by ophthalmology? Answer – Diseases and surgery of the eye.

Q. How long have you followed that branch of the profession as a specialist? Answer – Seven years.

Q. State what, if any, special training or teaching, if any, you have had in the science of ophthalmology? Answer – I have studied at the University of Vienna, Austria, London, Berlin especially. I was instructor in the subject at the Army Medical School, this city, for four years.

Q. Have you had a patient by the Name of William J. Sullivan? Answer – yes.

Q. Is he the William J. Sullivan who has a suit pending against the C&O Railway and the Southern Railway? Answer – Yes, so I am informed.

Q. State who brought Mr. Sullivan to you as a patient for your special treatment? Answer – Dr. A. B. Hooe.

Q. When did your treatment begin and when did it end? Answer – Began on September 23, 1915

Q. And continued up to what time? Answer – Until November 15, 1915

Q. During that period how often did you have occasion to examine his eyes? Answer – I saw him during that period perhaps every two weeks.

Q. For what did you treat him? Answer – For this condition of his eyes.

Q. What condition of his eyes? Answer – Optic neuritis.

Q. State in the record what you mean by optic neuritis? Answer – Inflammation of the optic nerves.

Q. Could the inflammation of the optic nerve that you mention have been caused by a shock or blow? Answer – Yes.

Q. What in medical terms do you call the cause of that condition? Answer – The cause or causes?

Q. Yes. Answer – There are a great many causes for this condition. Traumatism is one of them; Acute infectious diseases, inflammation of the nose, and parts contiguous thereto, asre the principal causes.

Q. Explain what you mean by traumatism? Answer – Injury.

Q. Is that an injury as distinguished from a disease? Answer – Yes.

Q. Did he give you any history as to what preceeded this condition of the optic nerve as found by you? Answer – Yes, he said he had been injured on the Southern Railway, February 23, 1915; that following that he had had a bloody discharge from the nose for some time, and that his eyes had felt weak and painful since that time.

Q. at your last treatment of him on November 15^th was he well. Answer – He had improved but he was not well.

Q. How does this condition that you found and for which you treated him affect the vision? Answer – It reduces the acuteness of vision and limits the visual field.

Q. Has it any other features that are distressing or anything? Answer – There is sometimes pain connected with it. It differs very greatly in different cases; and inability to use the eyes, particulary for near work, or to any extent without discomfort.

Q. Doctor, is this condition that you found usually or apt to be accompanied by headaches? Answer – I do not think so as a direct result of the inflammation in the optic nerve itself, but as a concomitant result of the injury.

after the depositions have been written up and read over.

(Signed Wm. T. Davis)

Subscribed and sworn to before me this 25^th day of March, A. D. 1916

(Signed) Wm. H. Holloway,

Notary Public, D.C.

Dr. Tom A. Williams, a witness of lawful age, being duly sworn, testified as follows:

Q. State your name, age, residence and occupation? Answer – Dr. Tom A. Williams; age forty six; 17o5 N Street, Northwest, Washington, D. C.; physician, specialist in nervous diseases.

Q. When and where did you graduate in medicine? Answer – In 1896, Edinburg University in Scotland.

Q. In what did you graduate? Answer – Surgery, medicine and midwifery.

Q. Have you practiced medicine and surgery ever since that time? Answer – I practiced until 1904, and then I began the study of neurology and practiced that since; at least, I practiced that since 1907, I was studying before that.

Q. will you state in the record what the science of neurology embraces? Answer – It embraces the structure and functions and disorders of the nervous system, and the brain, spinal cord, nerves, muscles and glands.

Q. state what if any special study you have given to that subject? Answer – I studied in Chicago, Boston first, and then I studied in Paris two years and a half, London with very distinguished teachers, and various clinics such as the London Hospital, Sal Petriere, Hotel Dieu in Paris, Massachusetts General Hospital, and the Cook County Institute.

Mr. Hall: I wish the record to show that the notice upon which service was accepted gave the

name of Dr. W. T. Davis, and also said “and others”, and we were not advised specially that the deposition of Dr. Williams was to be taken at this time. I must say it is a surprise to me to have this deposition taken. I realize the importance of Dr. Williams’ testimony and would like to reserve the right if necessary, to cross examine him at some other time.

Q. Doctor, does your study of diseases of the nervous system and the science of neurology embrace the condition commonly known as epilepsy? Answer – Yes, I am a member of the National Association for the study of Epilepsy in the United States, and have read papers before them.

Q. Do you know a man named William J. Sullivan who claims to have been injured by a wreck on the Southern Railway while he was a passenger in Prince William County, Virginia, on February 23, 1915? Answer – I know a man named William J. Sullivan who was referred to me for preliminary examination on October 5^th 1915, by Dr. A. B. Hooe. He said he had an accident in Virginia on the railway. I was asked to make an examination which I did after obtaining a history of the patient. I did not note the history of the accident because I presumed that was being done by others who were more competent to go into that matter than I, but I was particular in obtaining as exact a history of the facts as the patient could give it, and if you wish I will read it. I wished to find out if Mr. Sullivan had syphilis or not, and I arranged with the surgeon of the Southern Railway to conduct certain examinations, for which the Southern Railway remunerated me, and it was found that he had not syphilis. The blood tests were made and the spinal fluid taken and tested and found normal. The spinal fluid is almost never normal in a case of syphilis of that kind, although the blood tests may be in a considerable number of cases quite normal.

Q. Do you mean that you drew the spinal fluid? Answer – Yes, I drew spinal fluid from this man and it was examined in order to find out if he had syphilis or not, that was the purpose of doing it. I recommended a treatment which I have found useful in certain cases, namely a modification of the diet to limit the amount of proteins, that is food of the meat order, and an increase of the succulent foods such as vegetables, hoping it might benefit him, and prescribing baths. He found it too expensive to take them. He did not come back to me again, saying he had gone to the country to improve and would see me later. He made arrangements to take the baths but did not do so because he did not have enough money. While he took the diet there was no improvement, but it was worth trying. These are the main facts as well as I remember them at the moment. There are a great many other points that might be brought out by questioning.

Q. Doctor, state whether in your opinion this condition of bleeding at the nose, epileptic spasms and inflammation of the optic nerve, would indicate a fracture at the base of the brain? Answer – Not necessarily.

Q. Did your examination reveal whether or not there was a fracture at the base of the brain? Answer – It is not possible to find out that so long after the injury even with the X-Ray. There may have been a fracture which one could not detect, and then there may not have been. Such as a split fracture healed up.

Q. It is, or is it not a fact that epileptic convulsions due to what you have called traumatism from any cause, would be likely to increase as time goes by and the patient gets older. Answer – They generally do.

Q. Do you mean by that that the convulsion would occur more frequently? Answer – More frequently and sometimes they last longer.

Q. In these convulsions, what if any danger is there from the patient injuring himself? Answer – Not very much, unless he falls into a fire or falls in front of a vehicle, they fall down and bruise their heads and bark their elbows and cut their faces, but very seldom injure themselves seriously. If they fall against a projecting knob or a pavement they might fracture their skulls. In most epileptics there is a short period before the fall and the patient can get to a chair or get down on the floor. In institutions where they keep epileptics they do not pay any attention to the fall. They know they are going to fall and they go to a place where they can fall easily.

CROSS EXAMINATION

Q. Doctor, I believe you said that in examining Mr. Sullivan you have not gone into the history of the accident at all. Answer – I said I did not note it because I thought it was noted by others. I said he told me certain facts about the accident but I did not note them.

Q. Is it not true that the history of the accident would be of considerable importance? Answer – It was to me at the time. I based my conclusions partly upon the history of the case at the time, but I did not take notes of what happened. I do not remember it now.

Q. And your opinion, as I understand it, is based on the patient’s history to a very large extent, in conjunction with the findings of the eye by Dr. Davis, and the appearance of the face, the congestion of his face. Answer – Yes. sir.

Q. Do you or anyone else know what the real causes of epilepsy are? Answer – We know some of them.

Q. That is, the active or inciting causes? Answer – We know of some of the things. We do mot know how they do it; we know that they do; syphilis in certain instances, traumatism, metabolism, disorders, tumor of the brain, defects and deformities of the brain which are hereditary. In those cases where we get it in younger people.

Q. Alcoholism? Answer – Alcoholism is said to be a cause, chronic alcoholism.

Q. People are frequently predisposed to epilepsy? Answer – The alcoholic epileptic gets well when the alcohol is taken away.

Q. Under metabolism, would not over-eating be a possible cause? Answer – Yes.

Q. Would not that produce epilepsy? Answer – In certain individuals it produces epilepsy.

Q. Did Mr. Sullivan complain to you of loss of memory or something of that sort? Answer – I did not note it.

Q. He did not complain to you of uncertainty of the mind, confusion of the mind, loss of mental power? Answer – I am sorry to say that I do not know. I have not noted it.

Q. Would it make any difference in your opinion, doctor, if he had related one history to you and an entirely different history to another specialist. Answer – Not that my diagnosis would differ, but my opinion of his character would.

Q. And then it might change your diagnosis? Answer – I do not know until I heard it.

Q. Did he complain to you of any pain in his head? Answer – That I do not remember.

Q. And you do not remember whether he complained of confusion of mind? Answer – I have not noted it.

Q. Did he complain of vertigo? Answer – I do not think he did. I have read all I had of the notes.

Q. You have not seen him but once or twice? Answer – I do not know here. I could find out from my book. I have seen him, here I have noted, four times. Three times (counting).

Q. What time was that? Answer – In October and November 1915. There were four times.

Q. And you have not noted by personal observation his condition since November, 1915? Answer – I would not say that. I may have seen him in December but I have not seen him for some months.

Q. Do you know where he is now? Answer – I have no idea.

Q. When was it he told you he was going to the country? Answer – November 8^th of this year. I made the arrangements to take the baths and I have not seen him since then.

Q. I was much interested in a case cited by you in your article published in the Pacific Medical Journal --- Answer – What is it called?

Q. “Epilepsy in young adults and adolescents, with reference to a new treatment based upon patho genesis.” Answer – It was first published in another paper. Review of Neurology and Psychiatry of Edenburg and also in the proceedings of the International epileptic Association.

Q. The case of a man of twenty-four referred to you by Dr. Thomas Martin, September, 1911, on account of convulsions, and you treated him for epilepsy. Do you recall the case? Answer – Very well.

Q. And he had what you characterized as true epileptic convulsions? Answer – As well as I remember.

Q. didn’t I understand you also to say that he did not have attacks in his sleep? Answer – No, sir, I was speaking of nosebleeds.