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JOHN B. HAWLEY, CONSULTING ENGINEER, MEMBER AMERICAN SOCIETY CIVIL ENGINEERS. CITY ENGINEER, FORT WORTH,
FORT WORTH, TEXAS May 16th 1902
Hon. The Mayor & City Council_
Gentlemen.
Acting under your orders I have paved Jackson St-_ Between Cherry and Mason Sts.
I beg to suggest that the block between Macon and Florence Sts_ is in equally badif not- indeed worse_ condition
If it was proper to pave the block just finished_ due to its being a waterway- (practically a gutter)- it would seem that the other one should also be cared for.
Awaiting your further orders_ I am
Respectfully yours John B Hawley City Engr
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To T. J. Powell, mayor of the City of Fort Worth, or To John T. Montgomery, secretary of said City:
Now come C. V. Ingram, Jr., hereinafter styled petitioner, & gives notice to the City of Fort Worth, Tarrant County, Texas, that heretofore to-wit, on the 9th day of April, A. D. I902 he was traveling on the sidewalk on the East side of Main street between Fourth and Fifth streets going North, and that his foot come in contact with a the water-fixture on said sidewalk about tenseven feet from the Southeast corner of Main and Fourth streets; and that petitioner was violently thrown down, that by reason of said fall received the injuries hereinafter set forth.
Second. That said water-fixture was negligently placed and maintained on said sidewalk in such a manner that the same protruded far above said sidewalk, and that the concrete around and within four or five feet of said fixture had negligently been torn away at the time said fixture was so placed on said sidewalk; and that said City negligently failed to repair the same and that at the time of the accident herein complained of, said fixture and sidewalk were in an extremely dangerous condition to pedestrians; that said street and sidewalk is a public thoroughfare in the City of Fort Worth, Tarrant County, Texas. Third. That by reason of the said negligent construction and maintenance of said water fixture on said sidewalk, petitioner as hereinbefore set forth was violently thrown down and received the following injuries, to-wit: a deep, painful and dangerous gash was cut in petitioner's head; that his left leg was badly bruised, wrenched and sprained, and that his collar-bone was broken, that by reason of said injuries petitioner was thrown into a violent fever, that he suffered much pain both physical and mental; that his said injuries are permanent. Petitioner has expanded the sum of seventy-five ($75.00) dollars for medicine and one hundred and fifty ($150.00) dollars for the services of his physician.
Premises considered petitioner prays that he be allowed the sum of three thousand ($3000.00) dollars in compensation
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for said injuries, suffering and the expense incurred by him.
R. L. [Armstrong?] Jr. Attorney for Petitioner
