Pinkerton’s National Detective Agency vs National Pencil Company

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In the Superior Court of Fulton County, Georgia.

This the petition of Pinkerton's National Detective Agency, a corporation, respectfully represents unto this Honorable Court as follows:

1 The National Pencil Company is a corporation organized under the laws of the State of Georgia, having its principal place of business in the County of Fulton, State of Georgia.

2 On or about the 28th day of April, 1913, petitioner was employed by the National Pencil Company to render services as a detective agency in the matter of procuring evidence to convict the murderer of Mary Phagan, who was alleged to have been slain on the premises of the National Pencil Company in the City of Atlanta, Fulton County, Georgia, on or about the 26th day of April, 1913.

3 In pursuance of said employment petitioner rendered services as a detective agency for the said National Pencil Company from the said 28th day of April, through the 18th day of August, 1913.

4 The said National Pencil Company agreed to pay petitioner for the aforementioned services the sum of eight ($8.00) dollars per day, for each person used by petitioner in said services, and in addition thereto agreed to pay the expenses of the persons employed by petitioner in the aforementioned service, while so employed, and also to pay proper incidental expenses incurred by petitioner in this behalf.

5 On account of the services rendered in pursuance of the above mentioned contract the National Pencil Company is indebted to your petitioner in the sum of Twelve hundred and eighty-six and 9/100 dollars ($1286.09), besides interest from the 1st day of January, 1914, at the rate of seven (7%) per cent. per annum.

6 A statement of items making up the aforementioned account is hereto attached and marked "Exhibit A", and made a part of this petition, reference to which is prayed as often as necessary.

Wherefore petitioner prays that process issue requiring the defendant to be and appear at the next term of this court to answer petitioner's complaint; that it have judgment against the defendant in accordance with the allegations of this petition.

Robert C. & Philip H. Alston,
Attys for Petitioner.