From the Rolls-Royce experimental archive: a quarter of a million communications from Rolls-Royce, 1906 to 1960's. Documents from the Sir Henry Royce Memorial Foundation (SHRMF).
Legal letter discussing witness testimony and strategy following an accident at Hinckley.
| Identifier | ExFiles\Box 181\M10\ img132 | |
| Date | 20th March 1931 | |
| COPY. Claremont, Haynes & Co., Vernon House, Bloomsbury Square, W.C.1. 20th March 1931. W.Cowen, Esq., Rolls-Royce Ltd., 14-15 Conduit Street, W.1. Dear Mr.Cowen, Re Accident at Hinckley (GLN-60) I have your letter of the 19th inst. 2. I think it is very necessary that I should see Mr.Hives on this matter. 3. I have discussed the matter at great length with Mr.Claremont and we think that our sole chance of success depends on whether Mr.Hives and Mr.Lappin are able to give their account of the occurrence so convincingly as to make the Jury believe their version in preference to the story told by the seven occupants of the other car. Consequently we very much want to see:- (a) What sort of witness Mr.Hives turns out to be. (b) How his story fares when subjected to interrogation by us. 4. I think you will readily realize how important it is that such an interview should take place before we definitely commit ourselves to letting this action go forward for Trial. 5. With reference to the fifth paragraph of your letter, I enclose an Extract from the Statement of Claim in this matter which sets out the negligence which they allege against Mr.Hives. Needless to say a lot of it is merely 'stock'. (6) I will add that we have here worked out a very reasonable theory as to how the accident happened, but before putting it on paper we want to see Mr.Hives to see that his own version of the story tallys with our theory and that without our theory having been able to influence Mr.Hives's mind in this connection. Yours faithfully, Geo.H.Richards Tildesley. EPT | ||