https://haylibrary.cvlcollections.org/files/original/9055f23abd8bcf49ccb122dac942477e.pdf 05e9f8d38a0ddc2f13588a6b135eea5e PDF Text Text COlZPEHSATI ON CLAI M WASIL LEVKULICH E1.J:>LOYE OF LI ON COAL CORP ORATION Tra n s.crip t .of Tes t imony by Jay Go Wanner, MoDo A. , �October 24 1 1935 Mr. T. S.Taliaferro, Jrop Attorney Rock Springs , V/y oming . Dear hlr. Taliaferr o: I am returning herewith transcri p t of evidence given by Dro Wanne r in t h e case of Wasil -~ , _ . . ~......... =-~ - ~~v_!{ulich, an employe of the _Lion _9 oa:J,. .Com1J:anyo I found this . testimony very interesting and have had a copy made• for our files. very mu.ch for passing it to me. Thank you This shovv-s the tredn of what s.ome people are trying- to do and 1;vhich will probably get worse before getting bettero Yours truly, . .:. !_._. j i.....f.:..;r ·~J V' ; " ,.,, b 1/t£t:;3; �J. CO ... LT. I. ll. Daylooo . ~~lieing :.'.r .- Taliui' ~-1·0' r; lct-uo:.i;ocethor uitb. •<iho tootimoLY retorrocl to1 �C OP Y THE UNION PAOIFIC COAL COMPANY Rock Springs, Wyoming October 10, 1935 Office of Attorney hlro George Bo P r yde, Vice President and General Manag er, The Union Pacific Coal Company, Rock Springs, Wyomingo Dear Sir: I hand you herewith the testimony of t wo of our local Doctors taken in a case at Green Ri ver on the 2nd day of October, 1935, wherein Pal y, the County Attorney and others claimed an employee of t h e Lion C·:)al Company was permane n tly 51 totally disabled fro m insanityo This case involved someth ing around, I think, $ 8,000oOO. This case ,llill be of interest to you, because I think The Union Pacific Coal Company has one or t wo similar caseso I ·want you t .o read the testimony given by Dra ,'ianner, which illustrates the jeopardy vre are in at all timeso I find out that I make a mista ke in a former case, which mistake I avoided in this case, and I also avoided it in the Union Pacific case of Eugene Griglione. I 'think I told you the many letters and messages that I sent to General Attorney Loomis. I had this transcription made especially for the benefit of 1~r. Be.yless, and I ask you to turn it over to him when you have read Dr. 'Jlanner' s testimony. On second thought, I think it would be well for you also to get a good picture of how easy it is to get one Doctor in ten or fifteen togive testimony, which will support almost any outrageous claim. If Dr. ·:!anner ha d examined this vrnrlciilan constantly from the time that he went to the Denver specialists, the Lion Coal Company would have lost the case. It may be expensive, and this case was ex9 ensive for the Lion Coal Com·Jany, but we must send our patients to the specialists near the ti~-e of trial and after local Doctors have committed themselves. This case was expensive for me, the time that I put in on the case being worth a good deal more than the Lion Coal Company ;.- .•ill pay : ! e f or two :1ears. 1 Kindly treat this letter e,s confidential between you and Ifr. Bayless. Yours truly, (SGD) T. TST:kb s. TALIAFERRO, JR. �The State of Wyomin g ss. I N THE DI STRICT COURT County of Sweetwater ) In t h e l.fa t ter of t h e Cl aim -o f'.7AoIL L EVKULI CH , emp l oyee of t h e Lion Co al Co ml-'any , 1:1a d e under th e \'lo rkmen' s Compensation Lav, . Ho. 8215. Ex cerpts Tr w1script of ~roceedings -o- Green River, Wyoming, October 2nd, 1935. �;r. G. WAfTI\fER . a witness called herein on behalf of the claimant, being first duly s worn according to law, on his oath testified as fallows: Direct-examination by Ur. Ga licich: State your name, p le ase . ;r. G. Wanner. Q,. A. Where do you resi d e? Ro.ck Sp ri ng s, Wyomi n g . Q• A. A. ~- What is your busine ss or prof ession? Physician a nd su rg eon. Q,. A. Ho w lon g hav e you b een a physi cian and s urg eo n? About sevente en ye ar s. Q,. A. How long i n 1I!yomi ng? Fifteen years. ~A. You are of the re gul a r s chool o f med icine? Yes, sir . Q, , A. Do you kno v1 the injur ed wo:rkmo.n , Wa sil ·Levkulich? Yes, si r . Q. Have you ever at tended or excilllined the man in your profess ional c a_p aci ty? Ye s , I ha ve examined hi m several times. A. Q. • A. When d i d you fi1~st ex ami ne him? I examine d hi m first -- I co uldn't te.11 you the exact date, but it ,w.s in the hospital shortly after his injury. Q. • Do you know where he was injured? Do you mean the place? A. Q, . A. Yes. I understood he was injured in one of the mines in which he was employed, while at his duties. Q, . Could you tell us the month and the year of that first examination? I . don't believe I coul<i wi tri0ut referring to my office records. A. Q• A. Do you have them with you? don't have the records of the f'ir·st examination, but I have some records of the reports mttde since tba t time. I THE COURT: He was injur ed, Doc t or, according to the report of the employee, on the 16th of October, 1931. �2 A. Contin uing) I s aw him a:ppr ox i ma t ely pos s ibly on t h e 18th or liJth of tha t same mon t}). . r. Yo u ma oe en exami na ti o n o f h i m a t that ti me? Yes , I examined him. I e xamined one o f h is ears, on the injured side , be c aus e he h ad been ha vi ng some bl e edin g , and Doctor San aer s c a lled me i n t o s ee him . I b elieve he wa s su ppo s e d to have b een di z zy . 'Vi e ;v ere try i ng to loc a te the source o f his injury a t tha t time. I a lso exami ned s ome x-ray pic tu r e s of h i m . A, . Q, , .A . Q, . A. Q, , r .. No w, will y ou 11l eas e state t o t h e Court \· ha t y ou found as a result o f tha t examina tion'? At th a t ex amin c1 ti on , the ear d r um had evi de ntly bee n ru pture d, an d there was s ome bloody s eru m showi n g ov er that site a t tha t ex2.mina tion . The x - r ay p ictu r es -- I wa sn't able to see i n t hem any d ef ini t e f ra ctu re t ha t woul d i n dic a te a skull fr a c tur e . Th e man wa s we ak a na appea r e d d izzy wh en he s toa d up , and n o fu rth er exami na ti on wa s m&de by me a t th a t time. He >'las sent i n la ter to me for a check-up of his he a ring an d vi s ion. When wa s that? That w& s prob ably a " ou t a mo nth after th e time h e wa s in the hospita l . What d i d.. you fin d c:. t tha t time? A t t h& t ti me the man complaine d of lo wered v1 s1on -- very }:Joor visio n -- and he had many other symptoms of dizziness 8l1d. pai n i n h i s h ead . He comph:.i n ed o f not being a·ble to hear o n t h e one si d. e . Ky exam in a tion a t that ti:ne did not disc lo se very- much t o acco un t f or all o f tho se symptoms. I ex ~ 1i ea h im re_pe a te d ly, I vrnu l d say many times, a fter that. Som e of those ex amin a tions were not ma d e as a matter of record, b 1_l t they 1;1 ere mad e a s c a sual office examin a tions, e.na t h e:1 I made an exami na ti on o r t wo af ter that, when I believ e the coal compa ny sent h im, or- thr ough Doctors Lauzer and. Sa.nae rs, a nd then I made re [$ular reports of those examinations. 3ut his sympto ms ciuring, those pe riods never seemed to dovetail with the physical findin g s. :Jhen did you l u st examine thl s ma.n? refer to iflY records here? Q, . 1 J-. . }fay I ~A, Yes. I cannot tell you the exact date, but it vrns in September of 1 J 33, according to my last records, before he wa s sent to Denver. Q, , ,.'/hat did you find at that time? I was unable to find any physical eviaence to support the man's sympt0ms at a ny time. I considered t:i:1a t ei th.er the man was mali n 5 ering o 1· that he haci some s ymptoms or some A. �3 objective sign s which I coul d not correlate with t h e things h e c omplai ne d of . I s u g g e s t ed to someone -- I don't lmow whe t he r it was the Court or who it wa s -- a t tha t ti me t ha t th e man be sent for a comJ,> l e te neu ro l o gical a nd serolo gi cal exar.1 ina tion, a n sel ecte thre e or f our men in Denver to do this who h ad not p reviously ex ainine d the man. As I rec a ll, he had been exami n e d in a lt Lake a nd h a d been pronounced a ma lingerer, but, to give the man the benefit o f the doubt, vie selec te d t wo ou ts t an d in • me n in De nv e r. But y ou asJ<:ed me 'Jhat I fou nd . Th e man a lw ay s comp lained that he could not s ee . Th at w&. s his m i n comp l a int. He also com1lained th &t he va s dizzy , u. n he hc.d :p ain s in his hea d , a nd he could not hear 1.vith one e a r . I n my tests oi his vision, I wa s never a ble a t an y time to 6 et him to co - o p erate suff iciently to find o ut v,h et· er h e coula see o r not . He would refuse to r e a d a ny k in d o f a ch art . Wh ether t h e cha r t be he l d up t wenty fe e t fro m him o r wheth er it i,-,a s h eld up in f ront of his f a ce, he sc..i he coul dn ' t s ee any thin • , a lthou gh he wa s able to g et aro un d f a irl - s a tisf a ctorily . Q, , A. A, Q, . A. Q,, A. Q,, A. Did y ou ever see him a f ter t ha t exam in a tion i n 1933? I' m sorry, but I don ' t have my office r eco rd s v, ith me, an d I don 't know 1Nhether I d id or not . At least , I don' t b elieve I made any rep orts on h i m a fter tha t t i me . Did you ev er see hi m 'vhen he v,a s not a t your o ff ice - - that is, see him c a sually? I believe I have s e en him on the s tre e t, y es. Novi , I ,:,il l as _ y o u to st a te, fro m your ex am in a tion of the vrnrkman - - did you f i nd any p ermanent p hysical di sabi li ty, or did you find any -(Inter_LJosing) I ·woul d li ke to ha.v e tha t question put a little d if ferent l y , if p osEi b le, so that I may an swer it more intell i gently . Do you mean , d i d I find any objective signs, signs th&t I could see, of physical disability? Yes, objective symptoms. We speak of objective si g ns as something we can see, a nd subjective as something tha t the patient feels. I hc1.ve never been able to find any objective signs at all to account for his alleged trouble or symptoms. Now, in your opinion, do you believe tl1at there are subjective symptoms or that there is something wrong with the man mentally? Yes, I have formed a definite opinion in that regard through this period of time in which I had observed him and in readin.-:, the re1Jorts of the specialists wbo have examined him, and I have fanned a definite opinion as to what I think his trouble is. Q, What is that opinion? A. My opinion is that he has a condition known as post-trau.-rnatic �4 neurosis, or p sy chosis. I believe the man believes in his o wn mind tha t these thin gs a re wron g with him. At first I wa s incli ned to believe, li k e the oth e r men, t ha t the man v1 a s an out-and-out ma ling er er, but I am convince d now that he is not. I believe , if y ou wan t to so c all it, tbat it is a mil d form o f insanity. Q, . In y o u r opi nio n , is this mental con d ition due to the inj ur ie s whi ch he s u st a i ned i n Octo ber , 1 93 1? A. In my personal opinio n , it could be _p ossi ble . MR . TALI AFJi' RO : I object to tne answer anci move that it be stricken ou t. He aske d h im, in his opi nio n , did he consider his ment al condition no w the r e s ult o f the accident, and no w he says, 0 1n my p ersonal o pini on, I thinl< it might be pos sible" . Tha t is si mpl y a gu ess . THE COURT : s wer it. 11aybe that is a s definite ly as he can an- THE WIT.HESS : I mi ght qualify that, if the Court wishes, on this basis -- tha t t h ese qa ses a r e com~a ratively rar e, and much of our o inion i s f ormed on t h e pa st r ecord of similar c a se s t h a t we h a ve r ead ab out or have s e en co me up before other courts o f a si mil a r nature . 1Iy findin g s a re ba sed :princi p a lly u pon t h e i n terpretation of the re ports o f the other special_i sts who h ave exa.min ed t his man . HR . TALIA.FERR(:) : I object t o hi s bas in g his opinion upon rep o r ts of other speciali s ts that have examined him. This is not a hypothetical que s tion. THE COURT: Q• A. Q, . A. Q,. A. I think I wil .1 l et the a nsvrnr stand. Does this post-traumatic neuro sis d isable this man from performing work a t a t,ainful occup a tion? As lon g as it exists, yes. I wil l ask you to state whether or not, in your o,l)inion, the post-traumatic neurosis condition that you found to be present in connection with this case, or this p a rticular workman, Vfa sil Levkulich, is permanent or merely temporary. I am unable to _answer that ciefinitely, but, to quote again from the authorities on similar cases, I would say that many times in such cases as this, when any kind of a settlement has been made, either for the patient or against him, the neurosis will sometimes clear up when the patient's mind has been satisfied that the case has been settled. Doctor, are you a member of the Sweetwater County lunacy commission? Yes, sir. �5 Q,. A. Q. • A. Vlha t would you say as to the mentality of this workman? Is it normal, above normal or , below normal? Not knowing the man before his present condition, I would not be able to say definitely, but I would probably classify him as being somewhat below normal. From your e xamina tion of this man, Doctor, do you know definitely, or even approximately, when this post-traumatic neurosis was cievel oped or wh en it became present in the man to such an ext ent that he could not :perform work at a gainful occupation? I under s t and the man llR. TALIAFERRO : I object to what h e understands, if Your Ho nor p le ase . A. You mean, since t~'le injury? A. Q• Since the injury. It is my opinion that the trau ma tic ne uro s i s took place i!Ilmediately follo wing h i s injury. Q, . And was present at the da te o f your last examin ati on in A. September, 1 g33? Yes, sir. Q.. A. Coul d you state from your casua l observat ion of this man after t hat ti me whether t ha t con diti on still existed at the time you saw him, and. , if so, appro xima tely what time or date that VJ as? The only ·way I could an s v1er that is that the last time I personally s aw him and e.xan1ined him, it existed, and tn t a lki ng to ::!l.embers o f his family and others, the condition was app a rently the ea..--ne v1hen I would inquire about him. A. In othe r v1 ords, you keyt in close touch with this case sin ce its inceptio n to the p rese n t time, is that correct? Fairly close, through asking about his v1elfare from his other doctors and his wife a nd one or t wo qf his children that I have seen. A. I will ask you to state, to ascertain anci to realize that this traumatic ·neurosis condition exists -- can that be found upon one examination of a workman or does that require a continuous study of the case? There are certain cases of traumatic neurosis which· are demonstrated by actual physical findings, such as x-ray pictures, and there are some that we are not able to demonstrate and yet we know they exist. Q, . Q,. A, In which class would this one be? I believe this is a case in which no physical evidence can be shown in the way of x-rays or tests to support his symptoms. �6 Q, A. I will ask you, then, in a case like this, referring to this particul ar case of this man, V/ asi 1 Levh.7J.li ch, could some d octor, ·by ex amining him only once, determine whether or not he was sufferin g from tra umatic neurosis or · would it require ~n ob s erva tion over a period of time? I believe it would be necess a r y to observe a ny type of neurosis or p s ychosis to d etermine whether it was present and to ,vha t degree. !lIR . GiiLICICH: You may cross-examine. Cross-Examin a tion by iJ~ r. Taliafe rro: Q, . A. Q,, A. q, . A. Q. . A. Docto r, when did y ou form an op inion that the wo rkman or claiman t here wa s s uffering f ro m trauma tic neurosis? When did I form tha t opinion? Yes, when did y ou form tha t o_p inion? I believe I form ea. th a t opinion after the man wa s examined in Denv e r. Not until a fte r he v1as e xami ned in Denver did you form that opin io n? Ye s, s ir. Did you form that o p i n ion, a s y ou h a ve stated, from the report s tha t were received fro m these specialists in Denver and Sa lt Lak e? The r eJ!orts woul d indic a te t hat the man d id not have a traumatic n eu ro sis. ~A. An d you fanned that opinion af ter you had read these reports? Yes, sir. Q. • So th a t you didn't f orm y our o pinion as to the physical and men ta 1 condition o f this c l a i!llant from what these o th.er sur6 eon s ha Ye said? I was able to se:para te the v,hea t from the chaff, so to speak, a nd from the highlights of their findings, these complete re_t->orts, I was able to sift down and correlate them, a.nd I formed my opinion from that source rather than from what the doctors' opinions were of the case. A. Q. A. You testified at one time that you arrived at that conclusion as to the condition of this workman from \'!hat the specialists had said about him, v1 ria t they reported? I did. • ~A. You arrived at it from what they said? Yes, sir. Q. Anct it was, then, that you read between the lines ana determined that some of the things that they said were chaff and other things that they said were wheat? Yes, sir. A.. �7 Q• A. Q,. A. Q,. A. Q.. A. Q,. A. ii. A. Q,. A, Q. And that is the way you have arrived at your presen t con~ clusion? Not entirely. It is also from taking into consideration my past dealings person al ly with the patient and my examinations of him on many occasions. But you h a ven't e xan1ined him since he returned from Denver a nd Salt L a ke, except to see him on the street'? According to my records, I don't believe I have examined him. I say, you h a ven't examined h im since ·you sent him to Denver-: He h a s been s ince tha t, yes. He went to Mayos' since then. Have you exam in ed him since he ,a ent to :Ma y os''? No, sir. Then '.'lhat is t he use o f b ringing i n th a t :Mayo business? askin g d irect que s tions. Yes, s ir. - Now, the fact of the ma tter is, Doc t o r, in September, 1933, you made a st a te~ ent, did you, over your own si gnature, with Doctor Lauzer a nd Doctor Sand ers, t ha t you vrere unable to tell that this man v,a s suffering fro m any physical or mental condition, an a recommend ed tha t he be sent to other specialists? I don't r emember my re po rt without seeing it. I '11 sho w it to you ( h a ndi ng paper to vli tness). See if you reco g nize t his. See if y ou recollect it. I hand you a copy of a letter, and see if you can identify that as being a letter tha t you wrote. The ori gin a l, of course, is in Denver. Yes, sir. A. You wrote that letter, did you? Yes, sir. Q,. And the date of it? A. Sep te~ber 11th, 1933. Q. You haven't examined this man since t1i.en, have you? I don 1 t believe I have. A, Q.• A. Q, A. I'm That is what you have testified to. I don't recall any. On September 11th, 1~33, you addressed a letter to Doctor Franklin G. Ebaugh, 4200 East 1finth Avenue, Denver, Colorado? Yes, sir. �8 A. .Now, before going further into th a t letter, I will ask you if you recollect joining in with Doctor Lauzer and Doctor San d ers in a letter to Mr. R. Y. Gibson on March 22nd, 1933. Yes, sir. Q• In that letter, you st a ted Q, • Iffi. GALI CI CH: If the Court p lease, if they a re g oing to quote from t h e letter, wby not of fer it in evidence? The letters a re t he b est evi d ence, and we would like to see the letters. lIR. T.ALI AFERilO : I ' 1 1 in trod uce them, if you wa nt me to, after t h ey a re i de n t i f i ed . I1ffi . GALICIC H: But y o u v:e re a sk i ng wh a t wa s in it. weren 't identify in g i t. I.ill . T.ALIAFERIW: MR. GALI CI CH: bly save ti !'n e. You Do y ou want t o se e it n o v/? '/e woul d li k e t o s ee it. 1 We c an po ss.i - MR . T.ALIAF:&-qRO: I t h in k we c a n s a ve time if you will let me cross-ex~~ine him a s to his reco llection of the records. ( .'/hereup on, a ap er was m&.rked for identification as Employer's Exhibit A) . ilR. TiU:..I AFERRO: I i.'1ould like this letter to be admitted in evidence, if Your Honor please. J.ffi . GALI CICH: Q,. No objection. In this letter o:f }.larch 22nd, 1 ~33, marked Employer's E.xhibi t A, the following appears -11 \Ve examined him very- carefully and could find no evidence of any permanent disability as a result of _the accident, unless his present mental state is the result of the injury to the head. This cannot be verified by x-ray or any other means at our command 11 • A. Q,. Ana that is si~ned by Lauzer, Sanders and Wanner. Now, what other mea~s, since this work.man was examined by these Denver surgeons, has been developed by which you could find out personally, yourself, about this? You hadn't examined him, you stated? No, sir. What I am getting at, Doctor, is what you read in the reports of these surgeons. That was the only other means you had , i sn ' t that true? �g A. No, th a t is not true, in my sense of the interpretation of it, a s to what other means I had. I rely upon my au tho:citi es in medicine, possibly like an a ttorney relies on his a uthorities in le gal matt e rs -- his books -- and my opinion has been mol d e d d uring tha t time by my past observation of this patient pl u s the reyorts which we h a ve received since. ~- Plus t h e - reports? Yes, s ir. A. Q,. A. In othe r words , y o u h a v e chang e d y our o vm opinion of the ma tter with o u t s.ny f ounda t io n wha tsoever as to examination, exce p t the repo r ts of t fl e se Denver sur g eons? Yes, sir. Q,. A. And tha t is the way tha t y o u have cha n g e d yo ur op inion? I have chan g ed my o p inion by a correlati on of my p a st examin a tion s with t he a ddi ti o n o f thes e o ther rep orts. Q.• But those past examin ations we r e to t he eff ect, a ccording to your letter, t ha t y o u h a d no me a n s a t your co mma nd. That is why we sen t h im do r-m t here . A. A. Tha t is v1ha t y ou say - - tha t y ou h ad no means? Tha t i s ri gh t . A. Tha t wa s true when y ou se n t t h i s l e tter, wasn't it? Yes, sir. Q,. q, . A. Th e fa ct of t h e mcl tter is, when you co me down to it, that you have si mp l y chan g ed y our thou ght si nee y ou examined t h is man? Yes, I have. A. An o. that cl:1ante has been mca.de without any examination of him at a ll? Yes, sir. q, . And that change is in violation of the opinion of these A. doc to rs, these Denver surgeon gr Yes, sir. Q,, Q,, A. Now, Doctor, you say that you wrote a letter to Doctor Fra!1klin G. Iirbaugh on September 11th, 1933? Yes, sir. li.B.. TALIAFERRO: I think I will put this letter in, too. MR. GALICICH: No objection. ( \Thereupon, the paper in question was marked for identification as Employer's Exhibit B). �10 Q,. A. '\:Vha t is your specialty as a phy si ci an and surgeon, Doctor'? I specialize in eye , ear, nose an d throat. Q,. A. Wh a t is a neurolo g ist'? A neurolo g ist is a ma n wbo de a ls \ ith the brain a nd nervous sy ste;21, princi pally . ~A. Are y ou a s pe ci a list in t hat? No, sir. Q. In this lette r marked Emp lo ye r's Exhibit B, you sta te -- A. I h a ve been a sked by Hr . T. S . Tal i a ferro, attorney of the co a l compan i es h e r-e , to co nta c t a neurolo g ist in Denver for t h e purpo s e o f arrang in g an examina tion f or an employee of one o f t hes e co mpan i e s 11 - a nd y ou g o on fu r t h er and name Doc t or Edv,1ard Delehan ty. You a sk ed him to con ta ct a n eu rolo g ist? Yes, sir. Q. . An d then y ou fu r t h er say - - A. " As re gar d s con sult a tio n I woul d l ike to sugg est that you call in another neu rolo g is t in ren de rin g your report, and any of the follo win g men would o e a ccep t a ble 11 - a.n u then you g ive t h e n am e of Doctor Edward Deleha nty. 1fow, you testified tha t you a re no t a neurolo gist? No, sir, I 2.m not. 11 A. Do you kno·w Villi) Do eta r Delehanty i ff? Yes, s i r. He is a neurolo g ist in Denver. ~- Is that his special line in the p rofession? Yes, si r . Q, . A. Q,, A. Q. A. Q, A. Q• Do you reco {:,nize him as ·o eing a competent, efficient and skillful neurolo g ist? Yes, sir, he is a very goou ma n. You got a re port from him, didn't you? Yes, sir. Did you come to your conclusion or your opinion -- this opinion that has been formed since the report was given by Doctor Delehanty -- from that report, did you come to your conclusion that this man, this workman, was suffering from an insane delusion? If I ·believed his re.l:Jort, I would think that the man was m~lingering in putting on all of tho s e symptoms. So you didn't come to your present conclusion as to this ma.n's mental condition from anything that Doctor Delehanty, A. who is a neurologist, has said? Ho, sir. �11 A. Their report to y ou was exactly o:ppo site, wasn't it?. It fla s that he . couldn't find any evidence of any mental trouble with him? I don't rec a ll the gist of his r epor t. Q, , A. Gener ally, wa sn't tha t his rep ort to you? Generally, his conclusions, a s I remember them, v,ere that the man was a maling·erer an d tha t he had nothing wrong with hi m an d tha t h e was pu t t ing on . Q,. A. Either mental or physical? Yes, ir . ~- Therefore , the conclusion that you made was contra ry to what Doctor Delehanty informed you? Yes, sir . A, Q. J.L Q. . A. ~A. So his report didn 't enter a t a l l into this co n cl u s ion of y ou r s , this ne w conclu sio n Ther e v.' ere many things i. his report v:hi ch el i minated and cleared up po in t s that were not clec1.r in our minds as to othe r ment al and physi c2.l asp ects of the c ase . Do you kno w Doctor Fr ed S . Ha lsted? Yes, s ir. ~'ha t is his specialty? I thin k he d oe.;; e ~r , nos e mi thro ~t . I d on't kn ov1 v1heth er he c. oes e e work or not, but I know he does ea r, nose and thro at . Q. , A. Did you g et a reJ_Jo1~t from him? I hove a co py of his report, yes , sir. I don't know v/he ther it WciS sent to me 01· not, but I think I have a CO lJY here. Yes, I have a c opy of Doctor Halsted's re~ort here. ~A. Did you form this later concl u sio n of your-s from anything that he sai cl in his re.Qo rt to you? Not any more th..n I did from Docto1· Delehanty's report. GJ. i..nci. his r e_por t wa s agcJ.i ns t the f incii ng of any mental tro1.:."bl e A. I Q,, The fa ct of the ma.tter is, Doctor, thct you dic..n't pay much attention to what these doctors in Denver that you had referred this man to said, did you? The fact of the matter is I :paid -considerable attention to v1ha t they said. ,A. Q,. A. with this workman, vmsn' t it, as he reported it to you? c&nnot &1.n swer that without re ao in 6 his reliort over· . I cannot rernembe1· a ll that he said. in the reJ:)or·t. You vrnren' t guided by them in any \1.ay, v,ere you? In ma.kine:, a diagnosis, I make it by a. pr-ocess of elimination, and by readin 5 the reports I ·was able to eliminc:.te cert~in :fi:'.actors,, vjhich I appreci~ted ano valued their reyo:cts for. -- �12 A. ; . So y ou h av e c o1 e t o t his con cl u sion, not fro m subse quent exarniuation of t his wo r kma n , but from a nalyzin g the ref'Orts tha t these doctors ma de? Not entirel y . As I st te d before, it was fro m my correlation a n d my previo u fin d in b s in this c a se, plu s the s e reports. .do w , o n t he 11th day o f September, 1 ;;13 ::, , y ou st a ted to Doc- tor Ebe.u gh -t ha.s been my opin i o n from t h e very sta rt that the patient ha s mal i n~er ed , especially a s to loss of vision, a nd I am i n so me do u· t 2-. s to hi s los s o f hea ri n . : . This has a l so bee n t he o pinio n o :i.. other men ;;·1h o have examined him". 1 ' 1 A, Thu t was y ou r Ye s , s ir. though t in Sep t ember , l'd3 3, wasn't it? A. Who i s Docto r Eba ugh? Doctor Ebau gh i s conside r ed a ver r h i 5 h - cl as s man in his p rofe esio n a s a neurolog i st . Q, . A. In wl at? In neu rology. Q, . 0 . That i s , in menta l Qiso rders or n e rvous disord e rs? sir. J. . Yes, G. He is considered Yes, s i r . f... . Q,. ... . Q, . A. Q, , A, Q,. A. &. v e r y high - cl ass man ? And that is not y our sp ecialty? No, sir . And, no tv:i ths t anui ng t h e sta tements of Doctor Ebaugh m&.u e tc you, a.nd the statements that Doctor Delehanty made to you, wbom you reco mrnend as being high-class men in that line -- you <io, do you n·o t? I do. (Continuin€a.) -- you formed, since you saw their re:po1·ts, a. different opinion? Yes, sir. And you formed that opinion from their reports and not from an exami nation of thi s wo rkma.n? I didn't say that. ~A, But you said you hadn't exrunined him since? I said my present opinion is formed from my past frequent exciminations of the man, plus these re:f)orts. ~A. So you had no such past oyinion on Se~temner 11th, 1~63? My opinion before th&.t was that the man was malingering. I am frank in so stating that I thought the man was a ma- �13 A. Theref ore, y our opinion since that time, or your present o pinion, is ai)p a rently f ormed in the face of the reyor·ts of these sp ecialists that you ~eferred this man to? Not en ti rely. From what , i f you h aven't ex amined him? i\{y op inio n has been forme d by the study of case re1,1orts and. re a.ding o f au tho ri t i es on similar cases , ana it is my o p inion t ha t there i8 n o methoci of ex ami na tion that can demonstrate any s u bj e ctive evi ci ence o f in jury in this man . VThy di d y ou sen a t ]:,. .is workman , a t your request mad e to me -,·;by did y ou send him to Denver to b e examine d by these doc- A. QV . A. Qu . A. tors. In order to c l e a r the c a se up , if :po ssibl e. You at that time h d n o o _ inion of t h e ma tter , and y ou weren't an exllert in tha t ma t ter? biy op inion wa s tha t t he man vm s a maling er e r . Vlha t b a s oc curred s i nee t hen t o change that opinion? I \'li 11 repeat wha t ha s occurre d . I ma k e my d ic.1.~no sis by a proces s of e li mi n a tion . I h a ve ak en into con s i a. era tion my past examin at ions of the man , a nd my t h o u 5 hts a nd op inions a t that ti me, and the r e11 orts tha t were furnished by the Sc::.lt Lake docto rs a nd the Denver d octor s a.n d th e Mayo Clinic, and. my re adin g o f medic a l b oo ks , books o f au thorit;y, on s i milar cases, and. tha.t h a s mol ded my pr esent op inion. .ti. . That has mo ld ed y o ur present op inion? Yes, s ir . Q,. J._. .Anci i t has cr...a.ng ed s ince Se1>.temoer , l (J33? Yes, sir. Q, . A, And you are not an exJ:)ert upon mental a nd nervo u s diseases? Jfo, sir. Q. Will you give me the doctor books that you h a ve read, that you have referred. to that you have read, upon this matter of ment2.l disorders, since the 11th day of September, l'i:133? I don't sup11ose I could quote all of them to you. V A. Q,. I asked you for the names of the books. I say, I don't sup:i;io a e I coulu quote all of them, but I hcve read \'/ebster' s Legal I.'Iedicine ano To.xi cology and Warbasse on Surgery. Q,. Did they deal especially with traumatic neurosis? That is the su-bject I wa s interested in. ...... " AQ.• A. dian't ask you that. especially. Yes, sir. I I asked you, a.id they deal with it �14 A. You re 2.d them. Don• t you know whether t h ey cieal t with this or not? They did n ' t deal \\T ith this case, but they dealt with similar cases. Q,. A. Did they de a l with thitJ question? Yes, s ir. Q, . 'Iha. t is t wo a uthorities? Yes, s ir. Q,. A. Q,. ,A. 'When did y ou re ad th em, Doctor? Oh, I re a d them, one of them, wit hin t h e l a st week , bec a use I thought -- Q. To get re a dy to testify in t h is c a se? I thought I would b e c a lled upon t o give a n op i n ion. Q. • Then your op inio n fr om t h e s e books hc:.. s b een mad e 1:ri thin the last week? ~To, sir. i. A. Q,. A. Mo w, r eu.cii nt:,; the s e t viO boo k s has inf l u en c;ed your op inion in this c&se, isn't t ha t true? .No, sir. They dici enlarg e my vie\".ipoint or- refreshed my memory, b ec a use I t h ouk,h I i:;ou l d be c a lled u yon to testify to v. ba t I thought trauma tic neu rosis was. 1 q, . A. q, . A. You s ay you a re not & n expert i n t ha t? No, sir, I Elli not. But y ou a re a specialist in eye, e a r, nose and throat? Yes, sir. c,i . That is wha.t you have studied, isn't it, :Doctor'? A. I h &.ve studied general medicine and surger>j. I serve on a lun e. cy commission, although I am not at a ll an e.x:pert on insanity, and do not pretend to be. ~- A Jucige of a court serves on a lunacy commission, doesn't he? Yes, sir. But I am not testifying here as an expert in this case as to mental conditions. A. Q,. A. Then what you have said here is not as an e.x_pert? Absolutely no. MR. TALI.AFElIBO: That i~ all, Doctor. �15 Redirect-e. amination by I\ii: r. Galicich: Q, A. Is that your o pin ion as a doctor of medicine? It is. MR. GJJ..I CI CH: Th at is all. ( Whereupo n , the ,·1i tne ss wa s excused) . -o - �16 E. S. LAUZER a witne ss called herein on b eh a lf of the claimant, bein g first duly sv1orn a ccordin g to law , on his o a th testified a s follows: Direct-examin a tion by Mr. Galicich: Q. • State your name , p l eas e. A. E . S. Lauzer. Q, . A. /here do you res i de? Ro ck Springs . Q, . A. V/hat is y ou1' 11rof ess i on? Phy sici an and surgeon. Q,, A. How lon g have you been a physi cian a nd su r g eon? Si n c e 19 0 5 . Q. At what p l &ce? A. Ro ck Springs. Q, . A. Were you in WyominiS a l l of tha t time? All of that time. Q, . A, You ar e a g r ad uate of what sc bo ol? University of Nebr a ska. Q, . .A . Do you know t h e injured ·workman, Wa si 1 LevkuliL:h? I do. Q, , Were y ou ever cc:1lled upon to tre a t him in your professional c a };Ja ci ty? Yes, s ir. .A . Q. A. Q,. A. I will ask y ou to sta te whether or not you were called upon to treat him in your professional c a:pa ci ty during the month of October, 1931. Yes, sir. On what date? October 16th. Q,. A. '!n.1ere did you firs·t see the workman? I sa;w him first at the hospital. Doctor Sand.ers went first to the mine and picked him uy and brought him to the hospital. Q,, A. You say he was injured in the mine? Yes, sir, the Lion coal mine. ~A, Did you see him the same day that he was injured? Yes, sir, I saw him after he entered the hospite.l. �17 Q., A. State to the Court what you found in your examination of the workman. At that time I found he ha d a sli ght l a c e ration on the right side of the h ead, some what ov e r the right temple, and he was bleeding a little from the ri ght e a r. He was in a slight stup or ana a state of shock at the time. A, Was he consciou., or unco n scious when you saw him? He was semi-consciou8, Q, A. Ho w lon g d io he s t ay in t h at semi-conscious condition? About t wo d ay s. ~- Was he your p atie nt? He wa s treated b y me, y e s , sir. Q., A, And by whom else? Doctor Sanders. Q, , A. Doctor Sanders is y o u r a ssociate? Yes, sir. Q,. A. ~l - How lon g did you tr e at this ma n? tree.ted him right alon g . I h ~v e tre a ted him until the present time. A, I Q, . A, ·when did you last ex amine him? The day before yesterday he \"la s at the office. Q, , Did ~.1.r. Levkulich suffer a ny d i sa.bili ty, any physical or objective disability, as a result of that accident, and for how long? He v1as -- you mean ho v: long has he been di sabled? A. Q, . A, ~A, Q,, A, Yes, hovi long ·as he di sabled, that you could show and see his di s-.bi li ty? He left the hospital on the 24.th day of October of the same year, 10~1, but at that time I didn't fi~ure he was abie to work, and it has been going on up to the present. We hever have been able to decide -- that is, at least, I haven't whether he has any physical di sabi li ty now or not. In your examination of the worlrnan the day before yesterday, did you f inci any disability whatever, either physical or mental? The only thing I could decicie anywhere near was that he had some kind of a mental depression, but what it was, I could not sey, but as far as any physical defects, I couldn't find any. When dia. you first discover this· mental disability? Oh, it was sometime after he went home, but I don't know how long afterwards. �18 Q. . A. A, Q, . A. Do y ou h a ve a ny i d ea a s to the approxima.te time? No. I . t h in k - - that is, he wasn 't entirely -- well, I just couldn't say, but some time af ter he wen t home, because he was sort of depressed while he was a t the hos p it al, a nd then vve t h ought vi e would 1 et him g o home a nd it would probabl y cle a r up a little ·better , but it appar en tly didn't and it is stil l there . Would you say this mental con d.i tion is the result of the injury t hat he susta ined in October, 1931? No, I v:oul o.n ' t, b ecc.use I can't prove it. I don t know. What i s y our opinion in the matter;' have alway s f el t th at there mus t be some conn ectio n between hi_smental con dition now a nd th e acci den t, but I n e ver could _p oint out any thin g tbat I could ab solutely st and o_n by a n y method of exa.rnin&.tion. My o ,inion i s that I Do you mean physically? 1?hysi c ally or any other w y . Q, . A. Q. . What is the extent of this man's dep ression o r mental disability? Does i t inc&pac i tate him p a rti a lly or totally'? It appa rently is t o tal . At least , he feels t hat way . Would you say that his ment&l con di tion is :permane nt or merely t em Jora ry'? I do n 't know. It has been goinG on so lon g , I don't know rhether it is permal'len t or wh ether it is something that s til l m&y be cle ar ed up . Do y o u know hov. he su s t a i ned h i s injury? A timber hi t hi m on the he 2.d . Q, . A. The excilllination s.b.ow e d t-l1C4t he was struck by a heavy object? Yes. Iffi . GALICICH: You may cross-ex amine. Cross-ex&~ination by Mr. Ta li a ferro: Q, A. '{ , A. Q,, A. q,. Doctor, all you kno w ariout any mental 0isorder th a t he h~s is V!l'.Jit he says himself? Thfat is all. Tha t is all, but we can't prove it. And you don't knov1 v1hether what he J;3ays if feigned or fraudulent or whether it is true'? No, I don 1 t . I don't know. And y our conclusion wa s entirely drawn from what he tell 8 you? Yes, sir. Are you an expert, Doctor? Is that your specialty -- in men ta.l 2,nd nervous diseases? �19 A. No, sir. Q, • You concurr e d with Doctor ~a nner that this man should be . sent to sp eciali s ts on nervou s diseases? Yes, s ir, bec ause we felt we were not ab le to mak e a neurological exam i na tion. ('\ I,' You coul <in 1 t fi n6. any evid ence o f mental dise a se except wh a t h e tol d y ou? Tha t is a l l . Q. Do y e u kn ow Doctor Eo.v1&rd De lehan t y? Yes, s i r . Q, . A. ':lb.a t i s his r epu t ati o n a s a ment al s ur eo i a nd :physician? He is one o f the hi 6 hes t cl ass men in th&t lin~ in this west ern country. Q, . Would r..i s op i nion hav e i nfluen c e v i th you a.s a physician a nd sur g eon on a me ntal matte r? Yes, sir, it would . I wo u ld s · y it , ould . " A. A. Do you kno, Doctor Ha lsted? No, I don't. I h ve hear d o f h i m, b u t I don't kno¼ him. Q. . A. Do you kno w o f h is r evuta ti o n? I have hea r d of him by reput &tion, yes . A" . ':lha t i s i t ? He i s a nose and t hroat sp eciali s t, a s I rec a ll it. Q, . '!mat ie his re_pu t&tion in th a.t fie l d? It i a good. A. You don't know him personally? lif o , I Q. . A. do n ' t. But you do know Doctor Delehanty? Ye s , sir. Do you know Doctor F. B. S te~henson? lfo , I don ' t. Q,. A. Q,. b.. Do you knO\'i anythin€, about his reputation? I can't say that I do. Do you know Doctor Ebaugh? I don't know him per son ally, but I know him by repu ta tio 11, and I hc.ve had corres}londence with him. What is his specialty? He is a neurologist and psychiatrist. That is, mental and nervous disorders? Yes, sir. �20 Q, , A. '?Jhc..t is his reputation? Very high-class. :i,. .'/oul d y ou 'oe influenced in formin g a n o pini on by v.'ha t he s a i d? Yes , I would. .A . In a men t"'"l c ase? sir. Ye~. Do y ou kno 1,• Do ctor Y:: erby of S& l t L a ke City? -Ye s , ... i r . A. Q, . A. A. \','hat is h is r y ec·a1t? x - ra;y· . ·:rh a t i E> h i s r e1rn ta ti on ? I s he s J.r...i 1 f u 1 i n tha t ? Yes, s i r , first - clQss . In the ex a.mincttion o f a n x -r a , woul d you be g ui d ed in a n y ·way b y his stu temen ts? Yes, I wou l d b e incli ned to ~ cc~ t his d i agnosis. Do you knoD Docto r ~d~in ~ . son l eh e r? Yes . 1:lh a t is h is speci a l ty? Sye , e ~r, nose and tl1r o a t . Do you know him ~e rso~ally? Yes. Q, , i-. . Q. i .• :lh2:.:t is his st /;(nd i t1 0 as a syecial ist in t hat regard? High-el a ss . 1 V/oula yo u be g ui ded a 6 ood aeal oy wha t he said? Yes, I v;o uld, in tl-.1.&.t line·. A, I mec;.n , in thc2 t special branch of medicine and surge ry? Yes, I v10uld. ~A, Do you kno ~ Doctor Foster J. Cur tis? Yes. Q, . A. Of Salt Lake City? Yes. 1, , A, What i s hi s SJ:) ec i a l ty? He is a neurologist. Q, , Q, ~ ental a nd nervous diseases? i-... Yes. Q, 1... . Do you know him personally? Yes, s ir. �21 Q, . A. Q, . r. .n.. 'i \That is h i o r epute. tion d i s eases? Ve r y h i gh- class . c..l S a sJ:)eci al i s t i n me ntal a nd nervo u s Wh at woul d y ou think of a r e .J:)o rt made by him? Woul d y ou be influe nc ed by it? Yes , I would . I v1ould g, ive it dee) consi d e ra t i on, a t le a st. You t hink t~-iey &re wo rthy of consideration? Yes , ~ir . MR . TALI 1J!'11 0: Th· t ' s a ll . by l'l r . Galicich : Q, . A. Goin g b a c k t o the wor l<wan , ".'/ asil Levkul i ch, Doctor, i n your opinion , woul y ou s2.y t h i s man is a ma lingerer o r t ha t he is ac t ually suffering from 2. men · al d isorder-? I n e ve r felt , a s I ta te d before, tha t he wa s a mal i ng erer , en tirely . There uere some thin ss th&t h e exag ge r a t ed -no question c1 bout it - - "t:, u t hoY: much, I coul<.ln' t decid e. You wo u l dn 't s y he is tot a lly mali ngering? No , I v,o uldn ' t . <t • A. Do you feel there i s a ment a l a i ab i l i ty in • ddi tion to ma.li n 5 er i ng? Yes , I do . Co u l ci. you esti mat e that , o r in any way give the Court some i o. ea &s to how much y ou th i nk is pu t o n a nd h o w mu ch is a ct ually man t a l st a t e? I wouldn 't eveu a tt er.ro t to , becaus e it can' t be clon e . \l e c- n ' t ~ne .SJ.re i t. 'l'h~ t i s t he r ea son we s ent hi m t h e last tirne to the s!lay o Clinic, and t hey cou lc.n' t do it. THE CODI T: Is tha t lJay o Clini.c report _in the file here ': rl H. TALIAFERRO: lfo, sir, I don't think so, but I wo u l d n't object to i t bein g pu t in. !iR . GALICICH: Yes, that is agreeable vii th us. ( Whereup on, t wo p ap ers v,ere uw.rked for identification as Employer's Exhibit C a nti Employer's Report D) . Ex amination by the Court:Q, . .b. . !,'/ ha t is your interpretation of tha t report, Doctor? Tha t there is some rel a tion shi11 - - they feel the same a s we have ex~ressed here -- that there is some relationship bet ween the injury and. his menta l & tti tude, but 'H!lli t it is, vi e can ' t subst&ntiate, and there is no way oi' proving it. �22 H. ecro ss-exam in a tion by 15: r. Taliaferro: Q~ . A. Cal ling y our atten tion to th e l n st y a rag raph here -- "The presump tion is tha t injury induces structural c..: h an ge s of a sufficient a e g:ree to alter our subj ective processes" that simply 11ean s that there is presump tion? -Yes. A, (Continuing reaclin3) -- 11 but we are not in a position to find. physical e i gns to co r res1-1on d with them". Exactly, and tha t v1a s our thought -- we co u l d n't find it. Q. . A. Was t ha t y o ur t h ou 6 h t ? Yes, s ir·. Q. , 1:R . ThLI AF?JRRO : Tha t is a ll, Doc t or, so f a r a s I am concerne d . Examin2- t io11 by t he Court : Q, J.. . Doctor, a re y ou a c quainted :, i th these trauma tic neurosis ca s es? Do y o u us ually find :physic al :::yrnp to ms to explain the menta l con di tio n or n o t? "hi s trauma tic neurosis i s a co mp a r a t ively recen t disease, an<.i it is r a ther in d efin i te . That is, y ou may h ave an injury to a l eg , an d you have a p ecu li a r lot of symptoms tl1ere and yo u c an 't acc ount for t h em in a ny other way, but be c ause y ou hav e an inj u r it wo u l d be p rob a bly classed as a traumatic netu·osis. I n t hi s c as e, the injury is to the head, and these pe culi ar conditions have come on. I kne w this man before, and, of course, he \'las a little below normal intelligence t h en, but since then this has been agg ravated, but ~hethe r it i s the a cciden t or something else, we don·t know. 1 J.... 0. You ·.tone time thought he wa.s a malingerer, didn t you? :Not en tirely, no. I knew some of it wa s, but I never thought he was entirely a maling erer all the time. Q,, You still think that part of it wa s malingering? Yes, sir, I think part of it. A. Q. A. You think he is putting it on? Some of it, yes. Q,, A. But you don 1 t know how much? lfo, sir. \Ve can't differentiate. THE COURT: That's all. Recross-examination by Mr. Tali~ferro: Q.. Doctor, in Doctor Delehcmty' s cross-examination in this c a se, on Interrogatory No. 4, which is as follov,s: �23 A. "Stc..te a nd ex plain v1hat is me ant by tra uma tic neurosi s 11 and, in a nswer to tha t, Doctor Delehanty says this "'Tr a ume1.tic ne u rosis' is a term a pplied to a train of mental o:r nervou s s ymp toms whi ch develop following a n accident and which a r e c ause d b y other influences than trauma". Yes, that is tru e. Q,, A. It may be cause d by oth er thin g s except the blow? Yes, it may b e c aused by o th er thin g s. Q,, Arthu r L ee s u gests t h i que st i o n, Doctor -- May not neurosis d evelo p fro m a malin g eri ng a nd apart fro m a ny a cci- A. oen t? Tb a t i s po ss i bl e , ye s. A. In other words, a :person c an thi nk o f h i mself h avin g a di ·sea s e and beli ev e h e ha s a di se as e , h e n t here is no a isease? Yes, t i.la t is pos s ibl e. Q,. A. You h eard Doctor "lanne r's te stimony? Yes , d r , I di d . Q, • A. You 1 i st en e d to i t ? Yes, I di d . Q, . And he s a id in his testi mo ny tha t a p er s on who is a ma.lingerer a nd ,•;ho h a s thought a bout his cona i tion an d who has ma de himself nervo u s in s uch a way a s to a ffect his mind may cle a r u p when it is d efinitely detenni ned that he is to get comp ensation or that it is definitely asserted that he · is not to 5 et compensation. Did you catch that? Yes. Q,. A. ~. A. C'1, . A. In other ~ ords, either one way or the other, the matter mi ght clear up? Yes. 'l'ha t would be the man's o wn thought, v10uldn 1 t it, ra.ther than from the trauma? Yes, it appea.rs that v1ay. mR. TALIAFERRO: That's all. Hectirect-examination by Mr. Galicich: A. Now, in this p&.r·ticular case, Doctor, you are well acquainted with the m&tter as it proceeded in the courts, are you not', That is, you remember when the case was originally set for hearing in 1~33? Yes . A. Yes. Q.• .And then the man was sent to the doctors in Denver? �24 Q,, A. ~- A. Q,, A. ~A. And after the reports caxue back, the matter was dropped, so far as the man's claim wa s concerned? Yes, sir. And after the cas e was d ropp ed, did you notice any change in this man 1 s condition? No, I didn't. In other words , ther e wa s no change in his con dition &fter t h e c ase was dro p ped? No, it didn' t s ee,u to ma ke a ny d iffer en ce either one way or the oth e r. Now, Doctor, going back ta the questio n ·that Arthur Lee sugg este d , y ou s a i th a t a man could suffer from traumatic n euro sis eve 1 thou h the re wa s n o injury? No, I didn't s '""y II tr auma tic neuro si s 11 • It wo u l - be just a neuro sis. A. That is a di ff er en t ty.9 e of n eur o sis? Yes, t ha t is a little d i ff eren . . t yp e . Q, . A, That i s ca l 1 ed w:b..a t '? Psycho-neurosis. Q, . l'.ff . GALI CICH: Th a t 's all. ( .'/hereu pon, t he v i tness was excused) . -o- � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Union Pacific Collection Description An account of the resource This collection is made possible in part by a generous grant from Wyoming Humanities. All materials are the property of Union Pacific Coal Company, on long-term loan at Western Wyoming Community College. For usage inquiries, contact the <a href="https://www.uprrmuseum.org">Union Pacific Museum</a> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Compensation Claim Lion Coal Corporation 1935 Rights Information about rights held in and over the resource CC BY-NC-ND Date Created Date of creation of the resource. 1935 Subject The topic of the resource Compensation Claim, Lion Coal Corporation, 1935 Description An account of the resource Documentation of the compensation claim form one of Lion Coal Company's employees. Documents are held together by a brass pin and stored in an orange folder. Type The nature or genre of the resource Text Creator An entity primarily responsible for making the resource Jay G. Wanner, I.N. Bayless, T.S. Taliaferro Jr. Identifier An unambiguous reference to the resource within a given context 1-0243 Publisher An entity responsible for making the resource available The Union Pacific Coal Co.