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(7) Affiant states that she was a patient at St. Francis Hospital for a period of approximately 10 weeks, during which period many complications set in, including pneumonia and influenza. The operation on the hip and hip joint was for the purpose of setting same and placing a peg therein to keep same in place. Affiant states that during her confinement to said hospital she was under the constant attention of said Dr. White, and that during said entire period it was necessary that she take various drugs and have blood transfusions. During said period said affiant suffered constant excruciating and severe pains. On several occasions, affiant is advised, it was expected that she would die. Immediately after said accident causing her injury, affiant sent for her daughter, Evelyn, from Kane, Pa., who immediately came to Miami Beach, Fla., in order to assist in the care of affiant, and that the expenses of said trip and living expenses were paid by affiant, since her said daughter is without any personal financial means.

(8) Affiant states that she remained in said hospital, as hereinbefore stated, for a period of 10 weeks, and that during that period it became evident that said hip and hip joint were not healing properly; that thereupon she had herself transferred to the Jewish Hospital in St. Louis, where she has been a patient for the past 7 weeks; that in making said trip it was necessary that she be taken on a stretcher from the hospital to the train, the stretcher put through a window of the train, and that she was accompanied on said trip by her daughter. During the time affiant was in the hospital at Miami Beach, Fla., she at most times had the services of a private nurse. Upon affiant's arrival in St. Louis, affiant was taken by ambulance to the Jewish Hospital. Affiant's daughter immediately engaged the services of Dr. Gerhard E. Gruenfeld and Dr. Albert J. Key. Dr. Gruenfeld is one of the outstanding surgeons in the city of St. Louis, and Dr. Albert J. Key is one of the outstanding orthopedic surgeons of the United States. Numerous X-rays were taken of affiant's hip, and said doctors found, so affiant was advised, that the said bones had not properly healed, and that it was necessary to have a complete new operation. Affiant states that immediately thereafter she was operated on by Dr. Key. Affiant is further advised that in the course of said operation it was necessary to shorten the hip joint and hip bone, since the bone at the point of break had died.

(9) Affiant states that thereafter it was necessary that she have several additional blood transfusions; that she has been in the hospital in the city of St. Louis for 7 weeks, and that she is advised that it will be necessary for her to be in the hospital for at least 3 to 6 months longer, and perhaps even more, since it is impossible to state at this time what the result of said second operation will be. Affiant states that during all of said period she has suffered severe pain and is still suffering; that she is completely immobilized in bed and is unable to move her left leg.

(10) Affiant states that she does not know what the final outcome of the injury will be; she does not know whether she will ever be able to walk again; she is advised, however, that if she will be able to walk it will be many months before she can walk without a crutch, and that thereafter if she is able to walk at all, she will walk with a limp and will have to have a support of some nature.

(11) Affiant states that aside from the horrible pain and suffering which she has been compelled to endure, she has also suffered a tortuous anxiety caused by the constantly besetting doubt of ultimate recovery. Prior to the time of the accident affiant made a living for herself, and ever since the death of her husband, 19 years ago, for her children as long as they were dependent upon her. Affiant is now advised that she will not be able to get around again in the business world as she has in the past, nor will she be able to engage in the duties heretofore performed by her.

(12) Affiant states that in addition to the foregoing, she has been put to a terrifically large expense, one which she so far has been able to meet with the help of friends, but one which she cannot further endure. Up to the 1st of May 1943, her expenses have been as follows:

Nurses.

Hospitals

Railroad (Florida to St. Louis).

Doctor bills 1_

$378. 50 Blood donors_
871. 94 Ambulance..
115. 24 Hip brace_
320.00

1 This does not include any doctor services in St. Louis since affiant has come here.

$70.00 13.00 75.00

In addition to said expenses, affiant will have the expenses of her present doctors, including the expenses of surgeons who operated on her as hereinbefore set out, and hospital and nurses' bills which are accruing at the rate of from $100 to $125

per week.

Affiant states that in her opinion her medical bills alone will amount to approximately $5,000 and after all of these medical services have been rendered there is no certainty that she will be able to do anything by which she can earn a living as she has in the past, but, on the contrary, she will probably become dependent upon her son, who is approximately 25 years of age.

(13) Affiant further states that Lieutenant Alexander, who was then living at the Carlysle Hotel, witnessed the accident. Major Watts, in charge of the post, and Captain Sandrock are also familiar with the facts. Lt. B. M. Thomson of this same post obtained a written statement from affiant and from the two soldiers above mentioned, and also from Lt. Harry E. Randen and one Donald Doraheimer. Colonel Jones, commanding officer, B. A. T. C. No. 4, of the National Hotel, Miami Beach, Fla., is also familiar with the facts.

(14) Affiant further states that she has not employed counsel in this case to represent her, but has requested several of her friends, among them being lawyers, to obtain affidavits in support of her claim for compensation against the Government, and that this statement has been prepared for her by counsel who has represented her and members of her family for many years.

(15) Affiant states that said accident and injuries sustained as a result thereof were not due to any negligence on her part, but that on the contrary she was free of all negligence and that she verily believes that, as a matter of fairness and justice, she should be compensated.

FLOSSIE LEESER. Subscribed and sworn to before me, a notary public, this 25th day of May 1943. [SEAL] KAROL A. KORNGOLD, Notary Public.

My commission expires April 22, 1945.

STATE OF MISSOURI,

City of St. Louis, ss:

AFFIDAVIT

Flossie Leeser, being first duly sworn, on her oath states that this affidavit is supplemental to the affidavit heretofore given by her under date of May 25, 1943. Affiant states that she desires to supplement the statements in said affidavit of May 25, and supplementary thereto states

That after the soldiers in question ran into her and knocked her down, she lay on the sidewalk for about 15 minutes. An Army ambulance then drew up, and observing that the injured party was a civilian, drove away. Affiant states that she lay on the sidewalk for an additional half hour before a private ambulance was summoned. Affiant further states that the said injury caused a severe shock to her nervous system and that she has suffered, now suffers, and will continue to suffer, from shock. Affiant states that said shock and operation referred to in her previous affidavit produced many complications, including pneumonia, constant nausea, a urinary infection and secondary anemia; that affiant also suffered from several heart attacks, and numerous blood transfusions were given her.

Affiant states that for 22 months after her injury she lay in a hospital in Miami with her head lower than her body and her leg suspended in midair, with a 17pound weight pulling and stretching said leg.

Affiant states that when she realized she was getting no better in Miami, she made arrangements to go to St. Louis where she had friends and where she could obtain the services of the renowned Dr. Albert Keys, one of the outstanding bone specialists of the United States. Affiant states that she was advised by Dr. Keys that she would never again walk in her present condition, and that another operation was necessary to give her any chance to ever use her legs. Affiant states that she has been advised that while on the operating table she almost died, and was saved by receiving a blood transfusion and other essential emergency treatment. Affiant states that she does not know as yet whether she will ever be able to walk again; that up to the present time she has not been able to walk. Affiant states that she is still suffering from shock and that from time to time it is necessary that she have blood transfusions; that she is constantly being given liver extracts and that she is still suffering from nausea.

Affiant states that by reason of her condition she does not know when she will be able to return to her home in Tulsa, Okla. Affiant states that her nurse and

hospital bills are accruing at the present approximate rate of $100 to $125 per week; that she does not know what her doctor bills will be, and that she is without means to pay for the treatment currently being given her.

FLOSSIE LEESER.

Subscribed and sworn to before me, a notary public within and for the city of St. Louis, State of Missouri, this 12th day of June 1943. [SEAL]

My commission expires April 22, 1945.

To Whom It May Concern:

KARL A. KORNGOLD,

Notary Public.

WASHINGTON UNIVERSITY,
St. Louis, May 21, 1943.

I operated upon Mrs. Flossie Leeser on April 12, 1943, for an old ununited fracture of the left hip.

According to the history this patient was injured on January 24, 1943, at Miami Beach, Fla., when she was knocked down by a soldier. She was operated upon that evening by Dr. D. W. White at the St. Francis Hospital and the hip was nailed. She remained there until April 5, when she returned to St. Louis by amublance and train.

At the operation here the hip was exposed by the open method. The fracture was reduced, the old nail was removed and reinserted in such a manner that it penetrated the central portion of the head of the femur and the fracture line was impacted. Then, a McMurray osteotomy was done and the distal fragment was abducted and the two fragments were fixed by metal screws.

This patient is still in the hospital and it is my expectation that union will be obtained in both fractures.

If I can give you any further information I shall be very glad to do so.
Very truly yours,

J. ALBERT KEY, M. D.

D. WARD WHITE, M. D., Miami Beach, Fla., June 8, 1943.

To Whom It May Concern:

The following is the information desired on Mrs. Leeser's case:

1. Injury: Transverse fracture of neck of left femur.

2. Prognosis: Must be guarded as it is dependent upon person's ability to heal. 3. Length of time in the hospital: January 24 to April 4, 1943.

4. Difficulties which she had to endure: Operated on and Smith-Peterson nail inserted so as to bridge fracture. Many complications: Marked anemia, menopausal symptoms from operation in October, virus pneumonia, cystitis.

5. Amount of bill: $300.

6. How long Mrs. Leeser will be incapacitated: 8 months to 1 year.

7. How long she will not be able to walk without crutch: Unable to state because I have heard she was operated on in St. Louis and it will be dependent upon success of operation as to length of disability-probably another 6 months. Yours very truly,

D. WARD WHITE, M. D.

Mr. K. A. KORNGOLD,

Attorney, St. Louis, Mo.

DR. G. E. Gruenfeld,
St. Louis, Mo., June 5, 1943.

DEAR SIR: Here is a short report on Mrs. Flossie Leeser.

Mrs. Leeser arrived in St. Louis on April 2 on a stretcher from Miami Beach, Fla. She had sustained an intracapsular fracture of the neck of the left femur on January 24. She had been operated on for this injury by Dr. D. Ward White in Miami Beach, and had suffered a series of complications, among which I have reports concerning pneumonia, urinary infection, and a severe degree of anemia. On her arrival Mrs. Leeser was immediately admitted to the Jewish Hospital, and it was fouud that there was nonunion of the fracture, urinary infection, and anemia. It was evident that an operation was urgently needed to give the patient

the best chance for recovery from the fracture. taken care of by Dr. J. Albert Key.

This part of the treatment was

The other, secondary, conditions are still present. The patient requires continuous supportive treatment with liver extract and blood transfusions. She also suffers from febrile attacks of pyelonephritis. The prognosis concerning these latter conditions is most uncertain, since we found them to be drug resistant. At the present time the patient is confined to bed not only on account of her disability arising from the fracture but also due to the persistence of the urinary infection and the secondary anemia, which must be considered post-traumatic conditions.

Sincerely yours,

G. E. GRUENFELD, M. D.

POLICE DEPARTMENT, CITY OF MIAMI BEACH

STATEMENT OF ACCIDENT INVOLVING PERSONAL INJURY OR FATALITY

Name in full, Mrs. Flossie Leeser; age 52; date, January 24, 1943.

Residence: Wellington Hotel.

Business address: None.

Foreign address: Local.

Referring to accident of January 24, 1943, 5:26 p. m., at or near Thirteenth Street and Ocean Drive.

I herewith make the following voluntary statement:

At 5:26 p. m., I received a call to investigate a call for an ambulance at Thirteenth Street and Ocean Drive. A woman was reported to have been knocked down and injured. Upon investigation I learned that the above-named woman was walking on Ocean Drive at Thirteenth Street and two soldiers; namely, W. Pellit, serial No. 33479177, and C. Silknitter, serial No. 33479180, were playing hand ball alongside of the sidewalk. One of the soldiers ran into Mrs. Leeser and knocked her down. Her left hip struck the sidewalk and she was unable to walk. Mrs. Leeser was taken to St. Francis Hospital in a Riverside ambulance. At 8:35 p. m., I learned from the hospital that Mrs. Leeser has a fractured hip and is to be operated on tonight. The soldiers, W. Pellit and C. Silknitter both live or are stationed at the Carlysle Hotel.

EARL T. MACKEY, Police Officer.

I certify above to be a true and correct copy:

STATE OF FLORIDA,

County of Dade, ss:

M. V. B. SILVER.

Before me, a notary public duly authorized to take oaths and acknowledgments, appeared M. V. B. Silver, who after being duly sworn deposes and says that she is a clerk in the police department of the city of Miami Beach, and that she made the foregoing copy of the statement of accident from the original records on file in the office of the police department of the city of Miami Beach, and that she certifies that said statement of accident is a true and correct copy of the original report on file in the police department of the city of Miami Beach.

Sworn and subscribed to before me this 4th day of June 1943.

[SEAL]

M. V. B. SILVER. WESLEY M. MARTIN, Notary Public, State of Florida at Large.

My commission expires September 22, 1945.
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