Text Version


 
 
 
 
                                      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
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