MISS HATTIE HALL, Sworn In For The State, 41st To Testify

Reading Time: 9 minutes [1629 words]

`MISS HATTIE HALL, sworn for the defendant.

I am a stenographer for the National Pencil Company. I do most of

the work in the office of Montag Bros. Whenever it is necessary I go

down to the National Pencil factory and do work there. I saw Mr. Frank

about ten o'clock of the morning of April 26th, at Montag Bros. , when he

came over there that morning. He came in Mr. Sig Montag's office, where

I was taking dictation and I told him that I didn't know whether I would

be able to go over there that morning or not, as Mr. Montag was giving

me letters and Mr. Frank said: "Well, come if you possibly can. " He

had previously asked me over the telephone to come over to the factory.

That was about half an hour before he came over to Montag Bros. I had called him up to get a duplicate bill of lading and in the course of the conversation, I asked him if he would need me over there that morning, on account of his having an inexperienced stenographer over there, I had been going over there all during the month of April on that account. He said "Please come over, I have some work for you to do. " It was 20 or 30 minutes after that that he came over to Montag's. When he came in I told him that I was afraid I couldn't go over on account of the work I had to do at Montags, but Mr. Montag finished his dictation in a few minutes, and I then told Mr. Frank that I would have time to come over there and that I would be over there later. I started over to the factory between 10:30 and 11. I went alone. It takes about five minutes to get over there and I reached there before eleven o'clock. I don't know whether Mr. Frank was there when I got there. I waited in the outer office a few minutes before I started to work. I went in the inner office to get the orders to acknowledge for Mr. Frank. I acknowledged them for Mr. Frank. I acknowledged them in the outer office. I do the typewriting in the outer office. These are the 11 orders (Defendant's Exhibit 11 to 24, inclusive), that Mr. Frank handed me and I acknowledged. You notice my initials on them "H. H. " I put on there "Acknowledged, April 26th, by "H. H. "Mr. Frank got the orders when he went over to Montag Bros. and brought them back with him. The acknowledgments are the first step, in that case. Several people came in while we were working, two men, one whose son worked there came in and spoke to Mr. Frank about the boy's being in some trouble in the police court. They went into the inner office to talk to him and he came out to the outer office with them. Miss Corinthia Hall and Mrs. White also came in there in Mr. Frank's office and I talked with him. During this time Mr. Frank was not doing any work on the financial sheet. I find in this book (Defendant's Exhibit 12) all of the eleven orders which I acknowledged that morning, one order seems to be missing, I just find a requisition sheet for that. I did not enter those orders on the book. It looks like Mr. Frank's handwriting. I did not write any of these requisition sheets. The entering of the requisition was done after I acknowledged the orders, because when they enter them the house order number is put on them when they are put in the book and there was no house orders on them when I acknowledged them. Therefore, it had to be done afterwards. The requisition sheets are not made out until they are entered on the house order book and then acknowledged and then the requisition sheets are made. These eight letters (Defendant's Exhibit 8) were dictated to me Saturday morning by Mr. Frank and I typewrote them there in the outer office. After finishing them I took them in the inner office to him. I did not file these carbon copies, but left them with Mr. Frank. Throughout the time that I was there that morning with Mr. Frank he did no work on the financial sheet. As I was ready to leave the noon whistle was blowing. At that time I was in the outer office. I went downstairs, and remembered that I had left myumbrella, went back, got my umbrella and started out. When I pushed

the clock it was 2 minutes past 12. I did not see any little girl come along

about that time.

CROSS EXAMINATION.

The stenographer the pencil company had was inexperienced and

did only about one-third of the work and that's the reason I had to do the

other. I was getting $12. 50 a week on April 26th. I am now getting $15.

When I was first employed they said they would give me a raise on August

1st. I insisted that I be raised on July 1st, but they wouldn't give it

until August 1st. It was I that called Mr. Frank over the telephone. I

did not insist on going over there. He insisted on my coming. The acknowledgments consisted of stamping orders with a number, putting the

dates down there and acknowledging them by post cards sent to the people. Mr. Frank did not leave Montag 's with me. He left before I did.

He didn't know how long it was going to take me to write those letters.

Mr. Montag hadn't finished dictating to me when I talked to him, so he

did not wait. While I was there in the office, two men and three women

came in. The ladies came after the office boy had left and he said he left

about 11:30. The men were in the inner office with him about five or ten

minutes. I was in the outer office. I started to work type- writing about two minutes after he finished dictating the letters. I don't know how

long it took me to write them, I am not a very rapid typist. During the

time I was writing, Mr. Frank was in the inside office, except when he

came out to talk to Mrs. White and came to the door with those men. After

typing them, I took them into him to sign. He folded the letters and

put them in the envelopes himself. He did not ask me to stay until he

looked over the letters. As to what else there was to be done that day,

from the looks of the papers on his desk he had a good many to dispose

of. He went through them as he was dictating to me, and there were a

good many that he had to get rid of. I was over at the factory the previous

Saturday morning. He was not working on the financial sheet. I

got up for him the number of gross deliveries and the price and made an

average charge of how much each gross would cost. That was a part of

the data necessary for the financial sheet. When I testified before the

Coroner, I thought that was the financial sheet itself, because I had never

seen a financial sheet before. I know now that it was the average sheet. I

transferred some of those things to the average sheet. I never did see

the financial sheet. Mr. Montag gets it. I did not help Mr. Frank on the

financial sheet the previous Saturday. It was the average sheet I helped

him on. I discovered my error as to this being the average sheet and not

the financial sheet soon after the coroner's inquest. I know that Mr.

Frank was not working on the financial sheet on the Saturday morning

previous to the 26th. He was busy with something else altogether. He

simply gave me that data to work on. I did not identify the financial

sheet at the Coroner's inquest, I didn't even know it. I was not in Mr.

Frank's inner office on April 26th, excepting when I got the orders from

him. When I told the Coroner's jury, if I did tell them that, I didn't remember

being in his inner office at all, I have never been in a court room

before. I was so rattled that I wasn't exactly myself. Mr. Frank told

me that morning he wished Mr. Schiff would come over and finish the data, that he couldn't fix the financial sheet until Mr. Schiff got up the data, and he had Alonzo Mann telephone him to come over there to do it, but Mr. Schiff didn't come while I was there. I said at the Coroner's inquest that I didn't see Mr. Frank working on any of these books that

day, that I was in the outer office and he was in the inner office. There

wasn't any such looking sheet as the financial on his desk. When I was

in there he was at work on a pile of letters and things like that.

RE-DIRECT EXAMINATION.

When I was first employed at the factory Mr. Nix said to me, "I

will give $12. 50 a week, when the busy season opens up, about the first of August, I will raise it to $15. About the middle of June, I asked him to

raise it on the first of July, but he said, "We will wait until August 1st. "

At that time I testified at the coroner's inquest, I had never seen any of

the financial sheets. I did not write a figure on that financial sheet. At

the inquest I thought the average sheet was the financial sheet. I told

Mr. Frank that I couldn't stay longer than 12 o'clock, and he asked me to

stay all the afternoon and help him, that he was busy. I also heard him

ask Harry Gottheimer to come over in the afternoon.