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