United States Casualty Co. v. Leahy

122 N.E.2d 310, 68 Ohio Law. Abs. 425, 54 Ohio Op. 418, 1954 Ohio Misc. LEXIS 353
CourtCuyahoga County Common Pleas Court
DecidedAugust 20, 1954
DocketNo. 659356
StatusPublished

This text of 122 N.E.2d 310 (United States Casualty Co. v. Leahy) is published on Counsel Stack Legal Research, covering Cuyahoga County Common Pleas Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States Casualty Co. v. Leahy, 122 N.E.2d 310, 68 Ohio Law. Abs. 425, 54 Ohio Op. 418, 1954 Ohio Misc. LEXIS 353 (Ohio Super. Ct. 1954).

Opinion

OPINION

By BLYTHIN, J.:

This cause is before the court on the motion of applicant for approval of proceedings had in securing answers to applicant’s propounded interrogatories and the filing thereof, and for a voiding of cross-examination of the witness in a proceeding to perpetuate the testimony of such witness under favor of §2319.32 to §2319.38, both inclusive, R. C.

• Applicant filed its petition herein stating, in substance, that it issued its policy of liability insurance to The Better Realty Company, a Corporation, agreeing to indemnify the assured against loss resulting to persons from negligent acts of the assured. One James Leahy fell from a window on the premises of assured and was injured. Applicant claims that the assured failed to notify it of the happening as and within the time required under the policy and that Leahy, twenty-three months after the happening, brought suit in this court against applicant’s assured and that, as a result thereof, a claim may later be filed against applicant for indemnity. Applicant by its petition herein seeks to perpetuate the testimony of one Edythe Ebie and has listed and notified said James Leahy and The Better Realty Company as interested parties.

Attached to the petition and made a part thereof were 30 interrogatories to be propounded to said Edythe Ebie. An order was entered herein allowing the examination, naming John J. Mehler, a Notary Public, as the person to officiate in the premises and fixing the time and place to propound the questions and to record the answers of said witness thereto. The two interested parties were duly notified of all such details, or waived such notice. Both of the interested parties were represented by counsel at the time and place of questioning.

At the close of the answering of the interrogatories, counsel for The Better Realty Company expressed his desire to cross-examine the witness. Applicant’s counsel objected to any cross-examination on the ground that oral cross-examination is not authorized in such cases and situations. Counsel never[427]*427theless proceeded to cross-examine the witness and at the close of such cross-examination the applicant renewed its objection, having previously indicated its intention to move to strike both the questions and answers of such cross-examination in the event it later became necessary to use the recorded testimony of the witness. The questions put by counsel to the witness on cross-examination had not previously been presented, recorded or filed.

As already indicated, the motion now before the court is for approval of the taking and filing of the direct testimony of the witness, and also for an order of disapproval of the cross-examination.

THE LAW

The practice of perpetuating testimony is certainly not new; in fact, it is of ancient vintage.

Weeks’ Treatise on Depositions,

Sec. 11. P. 11. “Under the old chancery practice, original bills not praying for relief were of two kinds: 1st, Bills to perpetuate testimony and to examine witnesses de bene esse: and 2nd, * * *. In such cases recourse was had to a bill for perpetuating testimony; courts of equity having for centuries enjoyed the right of entertaining suits for the purpose of preserving evidence in perpetuum rei memoriam. * * * The jurisdiction which courts of equity exercise to perpetuate testimony has been thought to be open to great objections; first, it leads to a trial on written depositions, which is deemed m the courts of common law to be much less favorable to the cause of truth than the viva voce examination of witnesses. * * * and therefore there is no proper ground for deferring the proceedings to a future time, and thereby substitute written depositions for viva voce testimony.”

8 R C L No. 3. P. 1132.

“In equity there are two kinds of bills to preserve testimony; one is to examine witnesses in perpetuum rei memoriam, and the other is to examine witnesses de bene esse. The right to take the examination of witnesses before an officer authorized for that purpose, with the view of perpetuating their testimony, was fully recognized and established by the civil law many centuries ago, and is still recognized in the English chancery courts as a practice admissible, and, indeed, under certain circumstances, absolutely necessary for the protection and maintenance of the rights of parties. This practice is adopted in nearly, if not quite, every state in the Union.”

8 R C L No. 20. P. 1149.

“For the purpose of obtaining the testimony, interrogatories are framed by the complainant; a certified copy of these ac[428]*428companies the commission when it is delivered to the officer who is to act as examiner. As a general rule, such interrogatories are accompanied with the cross questions propounded by the adversary as a preliminary, very often, of the right to introduce the answers in evidence.”

8 R C L No. 28. P. 1156.

“If the deposition is duly taken under a commission awarded for that purpose by special order of court, with interrogatories thereto annexed in proper form, together with cross-interrogatories filed on the part of the adverse party, * * *.”

The above are quoted because of their clear suggestion that where the interrogatory is the method of taking and recording the testimony of a witness the cross examination must also be by interrogatory.

It is clear also that the right to cross-examine has always existed alongside the right to examine if testimony of the person examined is to be used upon trial of an issue.

Dean Wigmore in his Treatise on Evidence.

Sec. 1367.

“For two centuries past, the policy of the Anglo-American system of Evidence has been to regard the necessity of testing by cross-examination as a vital feature of the law.”

Sec. 1383.

“The principle requiring notice and opportunity of cross-examination applies equally to depositions taken in view of future litigation, ‘in perpetuum memoriam’; and it is preserved in the statutes as well as enforced in the judicial rulings.”

Sec. 1392.

“When a deposition is taken on written interrogatories filed beforehand, and the witness in an answer to a direct interrogatory departs from the subject of the question, the cross-examiner may be virtually deprived of cross-examination, because by not anticipating this answer he will not have framed his cross-interrogatories to probe the witness on that subject. This objection is obviously applicable to written interrogatories only; but to that extent it has a just foundation:”

Daniell’s “Pleading and Practice of the High Court of Chancery.”

No. 5 — Ed. Page 890.

“We have seen before, that, previously to the examination of a witness, a notice in writing of the name and description of the witness is to be served upon the adverse solicitor. The object of this notice is, that in case the adverse party shall have occasion to cross-examine the witness, he may have an opportunity of doing so. The cross-interrogatories ought to [429]*429be filed before the examination in chief is completed; and if they are so filed the party producing the witness is obliged to procure him to stay or return to be examined.”

16 Am. Jur. Sec. 38. Page 714.

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Bluebook (online)
122 N.E.2d 310, 68 Ohio Law. Abs. 425, 54 Ohio Op. 418, 1954 Ohio Misc. LEXIS 353, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-casualty-co-v-leahy-ohctcomplcuyaho-1954.