November 8, 1930.
RENGENESCHI v. ROOSEVELT
Dear Governor Roosevelt:
At the suggestion of Mr. O'Connor, I communicated
with Henry T. Hackett of Poughkeepsie relative to the
accident which resulted in the destruction of your Ford
Cabriolet. The only information I got from Mr. Hackett was
that contained in a letter addressed by him to you under
date of October 8th, a copy of which he mailed to me. I
then endeavored to get in touch with Mr. Rosenman for
further information but was advised that he is taking a
cruise. I am therefore compelled to trouble you for further
information regarding the accident.
After looking up the law quite carefully,
I feel that there is a fair chance of having the action
removed from New York County to Dutchess County. I think
that I should consult the insurance company, however,
as to whether their legal staff will attend to the removal
or whether we can assist them. Although Mr. Hackett is
suggesting the engagement of Edward A. Conger to represent
you in case the controversy is litigated in Dutchess County,
I assume that in view of the fact that you are now the
defendant and are covered by insurance you will let the
insurance company bear the burden and trouble of litigating
the matter. Although the insurance company ordinarily is
not obligated to endeavor to collect for you on any claim
which you may have against the driver of the other car,
nevertheless I am sure that they will be willing to
incorporate a counterclaim in the answer which you have
to file in the above action, in which counterclaim adequate
damages will be demanded for the destruction of the Ford
Cabriolet. If you will give me the name of the insurance
company, I shall be glad to get in touch with their
representative immediately, turn over to him the summons
which was served on you, and collaborate with him in the
matter of removing the action to Dutchess County and seeing
to it that a proper counterclaim is interposed.
Faithfully yours,
Arnold T. Koch