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Archives: Claim and Petition for Damage from Sophia Pierce
Your petitioner Mrs. Sophia M. Pierce (Mrs. N. A. Pierce) of said City respectfully represents that she is a regular registered physician and resides in the Fifth Ward of said City and has resided there for the last thirty years or more, that on April 28th 1890 she was called to attend a sick person at the house of Eli W. Moore who resides on Pontiac Street in said Ward and she went there about one o'clock at night and attended to the sick person, and left the house of said Moore about two o'clock at night, that the night was very dark and there were no electric lights or other lights to enable a person to see his way. Your petitioner further shows that the City Authorities of said city have made excavations on Pontiac Street on the East side of the house of said Moore so that they have lowered said street about twenty-five or thirty feet below the level of the ground at the East front door or said Moore's house, so that there is a steep bank about twenty-five or thirty feet high within four or five feet of the East front gate at the house of said Moore, that no fence or other protection and no danger lights were placed along said embankment to prevent persons falling down said bank in the night-time. That your petitioner left the house of said Moore as aforesaid and offered she was keeping a sufficient distance from said excavations to avoid all danger, that she had not taken more than two or three steps from the said East-front-gate, when she stepped over said bank and tumbled down said bank about twenty-five feet until she struck a large stone with her right-side, that she was rendered unconscious by the fall for some time and one or more of her ribs were broken and she received other severe internal injuries and also severely sprained her ankle and these injuries are of such a nature that your petitioner fears that she will never fully recover therefrom. That your petitioner by the aid of Mrs. Moore managed to go to her own house and was confined to her bed over two weeks by said injuries and has been able to do but little since said injuries. Your petitioner therefore requests your Honorable Body to examine into the matters aforesaid and allow to your petitioner such damages as she may be entitled to for said injuries. (signed: Sophia Pierce)
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