Peabody v. Pioneer Sand & Gravel Co.

In November, 1928, the plaintiff, Peabody, commenced this action in the superior court for King county, seeking recovery of a money judgment against the defendant company. Peabody, in his fourth amended complaint, upon which the cause proceeded to trial, alleged his cause of action as follows:

“I. That the defendant now is, and at all times hereinafter mentioned, was a corporation duly organized and existing under and by virtue of the laws of the state of Washington.

“II. That prior to the month of September, 1924, the plaintiff, being an expert in mixing and handling of concrete, originated,…