Q. Were you in the employ of the Pennsylvania Railroad Company, and if so, what position did you have on Friday, the 31st, of May last?
A. I was in the employ of the company as work train conductor of train No. 2 on Supervsor Hays' division.
Q. Where did your train start from on the morning of Friday?
A. Conemaugh.
Q. Who was your engineer?
A. John C. Hess.
Q. And who your fireman?
A. J. R. Plummer.
Q. Go on and state what you did during that morning, and where your train was.
A. We came to Cambria. Ww [sic] were ordered there in the morning to a slide that had come down off the hill and was blocking the south track. We worked there until they sent an order from the office at Johnstown, that came from "OD" office for me to go to a half mile west of Wilmore to a land slide that had blocked the tracks there. This was 11 o'clock in the forenoon. We left the west end of the Johnstown bridge at 11 o'clock and went to Conemaugh, and were stopped there on account of No. 8 laying on the eastbound No. 2 track. The train despatcher backed them over onto the north siding and left me go on east, when I went east of No. 6 bridge into what is called the deep cut, we were flagged by a trackman, and the tracks east of the deep cut, the north track had fallen into the river, and the south track was so damaged by the water that we couldn't get any further east. That was shortly after 12 o'clock.
Q. How far is it from Conemaugh to the deep cut?
A. Two miles and a half or three miles. Then I started and walkd [sic] to "MP" tower to report to "OD" office that I couldn't get any further as the tracks were gone east of deep cut, and when I went to Mineral Point tower, the operator could send no message west. He had no connection with the south side wires, and the north side poles were all down where this washout was east of deep cut, and I had to walk back to where my train was at the deep cut, and back back [sic] to "AO" tower, which I judge is a half-mile west of the deep cut or maybe a little more, to report the condition of the track, and that I couldn't get to Wilmore. That, I reported to Pittsburgh office, and they gave me orders---I [sic] told them that the tracks were giving way east of Conemaugh; No. 1 track had fallen into the river east of Conemaugh and it was working in pretty close onto No. 2 track,---and [sic] they told me to go back there and do what I could. I came back to about half a mile east of Conemaugh, backed down, and I though that track No. 2 wasn't safe to back over, and I stopped east of the washout and walked down over it, and examined the track, and I though I would put off the two hind cars and let them drop over it, and test the track, and I done so, and they dropped over all right, and then I cut two more off, and I had eight cars in my train and I let them drop all over two at a time. I asked the engineer if he thought he could fetch the engine, and he said he would risk it, and he brought the engine by itself down over it till we got past where the track w as [sic] giving way. Then we coupled our train together, and laid there, and there was a slide came down east of us on No. 3 and 4 track west of Buttermilk Falls.
Q. Do you think from your knowledge of the flood that day and the condition of the track east of Conemaugh, that it would have been safe, say at 12 o'clock, for Mr. Walkinshaw to have started out those two Day Expresses and the Mail Train that was there?
A. Oh, no, he couldn't have got them east of deep cut. They could have followed me at 12 o'clock right up to the deep cut but they couldn't have got any further. The north track was entirely gone, and the south track was undermined in under the north rail of the south track, which wouldn't have been safe for an engine and car to go over at all. For 20 yards, I counted the rails on the south track to see how much of the north track was gone, and I counted what I think would make 120 yards that was gone, and it was in under the north rail of the south track, which no eastbound train could have went over at all.
Q. So that in your judgment an order from Mr. Walkinshaw to have moved those trains with any expectation of getting them away from Conemaugh would have been out of the question?
A. They couldn't have passed that point, I am satisfied. Again I walked to Mineral Point tower and walked back there was a great deal more gone; there wasn't less th n200 [sic] yards of it gone, nearly double the amount, and still more going.
Q. Was the river very high?
A. Yes, sir, the river was very high.
Q. Did you ever see as much water before in the stream?
A. I was at Johnstown the time of the flood two years ago in June; that was supposed to be the highest it ever was; we were just making a change there about that bridge, and I was hauling rails\ [sic] in there to try to hold the trestling down. I was there from 11 o'clock in the forenoon; that was just th [sic] the time it got high, and in my judgment at 11 o'clock when I left there on this date, it wasn't less than four feet higher than it was then, or than I ever saw it. I was raised on the Conemaugh river just opposite New Florence all my life and I never saw the river so high in all my time, and I was raised right on a bottom on a farm that was liable to overflow more or less, and had a very good knowledge of the places it would come to on our property, and it never was so high as it was this time.
Q. When you came up to Conemaugh, were the tracks washed out just below Conemaugh?
A. Yes, sir, the river siding, it would be called No. L track west of Conemaugh, it had some of it been undermined then, and dropped down. I went up No. 2 track, that was the track No. 8's were standing on.
Q. Go on with your statement now
A. This slide came down at what we call Buttermilk Falls, and blocked No. 3 and No. 4 track. After we got our train down on solid ground where there was no danger of it going inthe river, so we could come back to Conemaugh in the evening, I ordered the man to go back up to this slide and go to work and clear No. 3 track. It wasn't more than two feet deepand about the length of this room (about 20 feet) on No. 3 track, and I went up with them, and worked on there until about 3.20 in the afternoon---I [sic] think it was about 3.20 or 3.30 anyway, when Mr. Pitcairn's engine and car came up--- [sic] I saw it coming but wasn't positive which track [it] was on. We swung on them, and they came on up;l they were on No. 3 track, and we had it cleared that we could let them pass right on. They went on and they had just got out of sight, and the men were still working and I was standing watching up through the gap of the mountain, when I heard a sound; I though at first it was R. P.'s engine and car--they [sic] had only gone up a few minutes--and [sic] I looked and they were out of sight. I still kept watching a little, and I still heard a sound, and I thought I saw the tops of the green trees bend on the flat between the railroad and the river, and I says the the men, "We'll get away from here", and I still looked, and then I was satisfied there was something coming. I couldn't see any rubbish or drift, but I saw there was a commotion among the green timber, and I hollowed at the men to run; we had to run, I suppose, 400 yards right west. The rocks where we were were [sic] perpendicular and so high we couldn't get up. We had to go between three and four hundred yards before w e [sic] could get to a place where we could climb the rocks, where there was a kind of path we went up, and we started to run, and as soon as this man Hess saw me running and the men running, he started and moved on down around the curve into Conemaugh with his whistle blowing; and as soon as we got where the path was, we went up the hill, and we hadn't got up on the top until it was just to where we started up. I
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