Frances Coles’ Tragic Last Days

In the Shadow of the Seven Stars
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Related songs: In the Shadow of the Seven Stars and Dead and Gone

Illustrated Police News February 21, 1891
Illustrated Police News depiction of the events

James Thomas Sadler and Frances Coles

During the court inquest into Frances Coles’ murder, a timeline of events was established for the days surrounding her death. Of particular concern was the whereabouts of James Thomas Sadler, a seaman who had just been discharged from his ship, the S.S. Fez. After his discharge, Sadler headed into Whitechapel where he quickly proceeded to spend all of his money on food and drink, a room and a female companion with whom he reunited at the Princess Alice Public House shortly after his ship ported at the London Docks. That female companion was Frances Coles, a 26-year-old woman who had been living day-to-day for the better part of eight years as one of the unfortunates who traded her body for a night’s lodging at a low-rent doss in Spitalfields and enough food drink to iron over the edges of a very rough life.

Frances Coles spent many of her remaining hours in Sadler’s company, sharing a double room with him on White’s Row and bar hopping around Whitechapel. The pair even went shopping together and Sadler provided the money for a new hat for Coles at a milliner’s store on Nottingham St. As Thursday, February 12 wore on, however, troubles began to beset the pair. In the early evening, Sadler was attacked and robbed by a woman and two men while Coles’ stood by watching. This incensed Sadler and he wondered if Coles’ had helped to arrange the attack. The pair split up for a time and, from that point forward, were in each other’s company only intermittently until the moment Frances was murdered under a railway arch in Swallow Gardens near Royal Mint Street in Whitechapel at around 2:15 AM on Friday, February 13.

James Thomas Sadler
James Thomas Sadler during the court inquest

Sadler was eventually arrested in association with Frances Coles’ murder but he was never formally charged. After being held for several days, Sadler was ultimately released without charges. Initially, many had wondered if Sadler might be the notorious Jack the Ripper; however, the record clearly showed that Sadler was away at sea in 1888 when Polly Nichols, Annie Chapman, Elizabeth Stride and Catherine Eddowes were murdered, so it soon became clear that he could not be the elusive ripper.

Of course, this does not mean that Sadler was not responsible for Frances Coles’ death; it simply means that there is little chance that he was the ripper. To establish that Sadler was guilty of Coles’ murder, the police needed to show that he had the opportunity, means and motive to commit the murder. The fact that several witnesses testified to seeing Sadler in a diminished physical state just minutes before the crime would prove to be a problem. Moreover, the fact that those witnesses included police officers who had tended to his wounds made it ever the more difficult for the authorities to believe that Sadler was the the man who committed the crime.

There was also the problem connecting a murder weapon to Sadler, even though he had a knife in his possession that night. It is a matter of record that he had suspiciously sold a knife early the next day to another sailor. However, once that knife was produced, it was clear to the authorities that it was not sharp enough to have been the murder weapon.

Consequently, once all the facts were in, many doubted that Sadler had committed the murder. His motive for performing such a desperate act was also not clear. It is true that Sadler was known to be a belligerent drunk, but there was nothing in his past to suggest he was capable of murder or that he had any particular hatred of women or prostitutes.

Illustration connecting Frances Coles' murder to the other killings
Was Frances Coles yet another victim of Jack the Ripper?

Furthermore, according to multiple witnesses, Sadler had not behaved like a man who intended to murder his companion; in fact, he had shown concern and compassion for Frances both before and after the murder, even making sure that her lodging that night had been paid for – even when he could not pay for his own. This show of concern was in spite of the fact that he suspected that Frances may have conspired with others to attack and rob him earlier that evening. Perhaps Sadler’s outward concern for Frances’ well-being on the night of her murder was just an act and he was already intentionally covering up for a crime he intended to commit later that night.

On the other hand, there was at least one other potential suspect. According to Ellen Callana (who is also known as ‘Ellen Callagher’), Sadler wasn’t the last man to be seen with Coles that night. Callana met up with Coles on Commercial Street near the Princess Alice Pub at about 1:30 AM on February 13. As the two women walked down Commercial Street toward the Minories, they were approached by a man seeking a female companion. Callana refused to go with the man because he had been rough with her earlier in the week, but Coles takes him up on his offer. Callana also testifies that the man definitely was not Sadler, whom she knew by sight. Consequently, between 1:30 AM and 1:45 AM, approximately 30 to 45 minutes before her death, Frances Coles walked away with an unknown but violent man in the general direction of the murder scene.

Swallow Gardens arch in 2009
Swallow Gardens in 2009 with a red circle marking the location of the murder

Nevertheless, Sadler was definitely in that same area of Whitechapel, arguably close enough to have encountered Coles at 2:15 AM on his way back to Spitalfields from a roundabout journey to the docks, where he was forced off his ship and beaten yet again by a group of sailors. Perhaps Frances was making her way in the opposite direction to find Sadler at the docks. Perhaps the pair did meet under the railway arches near Royal Mint Street, and maybe Sadler did find Coles in the middle of a sexual act with the other man. But, if that is the case, what became of the other man? Did he run? Did he fight? There were many passers-by just prior to and right after the murder and no one reported a second man fleeing the scene.

All we know is from the testimony of a few individuals who were nearby right before and after the murder (but somehow not during?). A police constable named Ernest Thompson testifies that he heard the footsteps of a person walking away from the scene of the crime at a normal pace at approximately 2:15 AM, but he never got a chance to view the potential suspect. He instead tended to the victim. In the meantime, whomever committed the horrible act disappeared into the shadows of Whitechapel with no one to witness his or her departure.

Meanwhile, James Thomas Sadler returned to their lodging, Spitalfield’s Chambers in White’s Row, where he inquired about Frances’ whereabouts and well-being for the second time that night. When he was told that Frances was not there and he needed to leave because he could not afford a room, Sadler eventually made his way to the London Hospital, where he was treated for the wounds he received from two fights that night – and possibly from one murder.

Sadler was arrested at a nearby pub the following day and was taken away peacefully. His main concern was that he get proper representation, lest the people get ideas of blood lust before getting all their facts straight. He also must certainly have been concerned that people were already talking about Frances Coles’ murder in connection with the Jack the Ripper killings.

Ellen Callana’s Testimony at Frances Coles’ Inquest

Ellen Callana (aka, “Ellen Callagher”), a prostitute lodging at 3 North East Passage, Cable Street, St George-in-the-East. Appearing on the fifth day of the inquest, she stated:

“I know the deceased woman, Frances Coles. I have known her for five years. I remember Thursday, the 12th inst., and saw her drinking with Sadler. I next saw her at 6 o’clock, and she was still with Sadler. At 1:30 a.m. I saw her again by the Princess Alice.”

She was asked how she could ascertain the times of her sightings, to which she replied:

“She told me she had been turned out of Shuttleworth’s, where she had been having something to eat. I went by the publichouse clock. I walked up Commercial-street towards the Minories with her, and asked her what she was going to do. A man spoke to me. He was a very short man, with a dark moustache, shiny boots, and blue trousers, and had the appearance of a sailor. It was not Sadler. Because I would not go with him he punched me and tore my jacket. Frances was about three or four yards away at the time. We were both just getting over drunkenness. He went and spoke to Frances then, and I said, “Frances, don’t go with that man, I don’t like his look.” She replied, “I will,” and I then said, “If you are going with that man I will bid you goodnight.” I left them at the bottom of Commercial-street going towards the Minories, and I went to Theobald’s lodging-house, Brick-lane. I watched them till they turned round by the publichouse into White-street. I first heard of the murder on Friday at 5 a.m., and in consequence of advice I went to Leman-street Police-station and stated what I knew. I was then taken to the mortuary and identified the body as that of Frances.”‘

“I have never told any one that it was 3 in the morning when I saw Frances with a man. I made a second statement to the police, and I then said it was a mistake. It was not 3 o’clock. I had been drinking with Frances on and off all the day. The deputy at Theobald’s lodging-house could tell the time I arrived there.”

Callagher was asked if she had found out this time from the deputy and she replied that she had – she arrived at Theobald’s at about 2:00 am.

References:
Inquest report, The Times, 28th February 1891

The following is a timeline of the events as they unfolded in those fateful days and hours:

WEDNESDAY FEBRUARY 11, 1891:

  • 7 pm: James Thomas Sadler is discharged from his ship the S.S. Fez at the London Docks.
  • 8:30 pm: Sadler walks to the Victoria Working Mens Home on Commercial St.
  • 9 pm: Sadler and Frances Coles meet at The Princess Alice Public House on Commercial Street. They leave together shortly after and visit other pubs in the area, including the Britannia on Dorset St., where they are joined by Annie Lawrence.
  • 10 pm: Coles and Sadler move on to The White Swan at 20 High Street in Whitechapel where they are served a half pint of whiskey in a bottle by the landlord’s daughter, Florence Davis.
  • 10:15 pm: Coles and Sadler take a double bed at Spitalfield Chambers, 8 White’s Row.

THURSDAY FEBRUARY 12, 1891:

  • 11 am: Sadler and Coles leave Spitalfields Chambers and head for the White Swan to return the bottle for two pennyworth’s of drink. The pair then go drinking in a number of public houses.
  • 4-5 pm: Head Barman, William Steer serves Sadler and Coles gin and clover in The Bell, 106 Middlesex St.
  • 5 pm: Coles is waiting for Sadler in Shuttleworths Eating House 4 Ann St, Wentworth St. As Sadler arrives Coles complains to Annie Shuttleworth that Sadler had said he would only be fifteen minutes. The couple sit down and have something to eat.
  • 5:45 pm: Sadler and Coles leave in the direction of Petticoat Lane. As she leaves, Coles tells Annie Shuttleworth that she would see her later.
  • 6 pm: Ellen Callagher sees Sadler and Coles out and about the pubs.
  • 6:30 pm: Sarah Treadway, Landlady of the Marlborough Head, 5 Pelham Street, serves Sadler and Coles three quarterns of gin and peppermint.
  • 7 pm: The couple leave the Marlborough Head and head for a milliner’s shop at 25 Nottingham St. On the way Sadler gives Coles a penny to purchase a pair of earrings from a little huckster’s shop at the corner of Brick Lane and Hansbury Lane.
  • 7:30 pm: While milliner Peter Hawkes is serving Coles, he sees Sadler standing outside the shop. Coles inquires about a bonnet costing 1s. 11½d. Hawkes notices she is very drunk.
  • 8 pm: Sadler and Coles return to The Marlborough Head. They are served beer and whiskey by Landlord Charles Treadway. Sadler buys eight lottery tickets for 2s. and gets a round in for some men he had met earlier.
  • 8:30 pm: Sadler leaves Coles in The Marlborough Head arranging to meet her later in a pub and heads off to Spital Street to meet with a man called Nichols.
  • 10 pm: Sadler meets up with Coles again. As they walk down Thrawl Street, Coles warns Sadler that it might be risky. He continues down the street where he is assaulted by a woman in a red shawl who hits him in the head with a bottle. Two men who are, apparently, with her kick him to the floor and rob him of his watch and all his money before running back inside their houses. Sadler is injured and has gravel rash on his face. The couple have a row on the corner of Thrawl Street since Sadler thought Coles might have helped him when he was knocked down. After the argument, the two part company.
  • 10:30 pm: Coles returns alone and very drunk to the kitchen of Spitalfields Chambers. Charles Guiver sees Coles take a bonnet from the folds of her dress and throw it on the fire before sitting down and resting her head on the table. A woman quickly picks the bonnet out of the fire, stamping on it to extinguish the flames and hanging it up on the hat rail.
  • 11 pm: Sadler arrives at Spitalfields Chambers and pleads with Guiver to allow him to speak to Coles to give her 1s. to pay for her lodgings. Sadler is allowed in and sits next to Coles but she is very drunk and not responding so Guiver helps Sadler clean up in the backyard. Sadler then comes back into the kitchen and sits next to Coles asking her if she has her lodging. Coles lifts her head to look at him but says nothing and lays her head back on the table. Sadler thinks Samuel Harris is the guv’nor and asks him if he can go up and get a bed if he gives him his wages check to mind until the next day but Harris cannot help him. Sadler becomes argumentative with some of the other lodgers in the kitchen.
  • 11:45 pm: Guiver goes to turn Sadler out of Spitalfields Chambers but Sadler leaves quietly.

FRIDAY FEBRUARY 13, 1891:

  • 12 am: Guiver tries to rouse Coles by asking her to have a wash and freshen up but fails. A woman wipes Coles’ face with a wet cloth. Coles wakes and without saying a word to anybody pins her old bonnet in the folds of her dress and leaves. Sarah Fleming sees her pass her office window as she walks out into the street.
  • 1:00 am: Police Constable William Bogan finds Sadler lying drunk in the gateway to the London Docks and pulls him to his feet by the collar. Sadler requests to be let into the docks so he can return to his ship.
  • 1:00-1:30 am: Joseph Haswell serves Coles 1½d of mutton and bread at Shuttleworth’s Eating House on Wentworth Street.
  • 1:30 am: Ellen Callana (a.k.a. ‘Callagaher’) and Coles are walking up Commercial Street after coming out of the White Hart on the Whitechapel Road when they meet a man dressed in a sailor suit with a pea jacket and a cheesecutter hat. The man approaches them and offers Callana half a crown. Callana refuses and the man catches hold of her, tearing her jacket and striking her in the eye before walking off with Coles down Commercial Street in the direction of Leman St.
  • 1:30 am: The keeper of Gate 1, London Docks, Constable Henry Sutton allows Sadler through the gates. Sadler tells Sutton that he is a donkeyman returning to the SS Empusa (or Enthusa) which belonged to the same company as the SS Fez, both vessels lying in the St. Katherine Docks. When Sutton sees how drunk Sadler is, he turns him back. Two dock laborers, John Dooley and William Harvey, who are being searched by Dock Sergeant Frederick Sessions as they leave work take pity on Sadler and offer to take him with them to their lodgings but Sadler is abusive calling them dock rats and strikes out at Harvey. Police Constable Bogan asks Sadler to leave the area or he will take him in. Sadler refuses and the Constable walks away. Sadler is then beaten to the floor and kicked in the ribs by the dockers. Constable Sutton comes out of the gates to break them up and the men walk away up toward East Smithfield, leaving Sadler to get to his feet and head off in the direction of the Minories and Nightingale Lane where he rests for ten minutes nursing his wounds.
  • 1:40 am: Sadler walks to the Victoria Working Men’s Lodging House at 40 Upper East Smithfield, but because of his condition he is refused a bed by a stout, fat man. Deputy Keeper John Johnson.
  • 1:45 am: Coles is asked to leave Shuttlesworth’s by Haswell so he can close the shop. He has to ask her three times and she tells him to “mind his own business” and is shown to the door. She turns right towards Brick Lane. Haswell notes that Coles is tipsy “but knew what she was about.”
  • 1:45 am: Sadler appears in the lobby of the Melbourne Chambers Common Lodging House in East Smithfield. He arrives only ten minutes after the two dock laborers Dooley and Harvey. Harvey has gone straight to bed and Dooley, while making himself some tea in the kitchen, sees lodging house keeper, George Peakall, refusing Sadler a bed and urging him to go to the Hospital. Sadler leaves, remarking “You’re a pretty lot of beauties. You call this a Christian country.”
  • 2:00 am: PC Bogan and Sgt Wesley Edwards speak to Sadler opposite the Mint. Sadler complains to Sgt Edwards of being beaten up outside the Dock gates and that PC Bogan had turned his back. Bogan denies seeing the incident and Sadler replies “No. You dirty dog. You took particular care not to see it. If I am an old sailor and drunk I ought not to be treated like this.” Sgt Edwards and Sadler walk on for thirty yards and stop opposite Lockhart’s Coffee Rooms at the corner of King’s St and Tower Hill where Edwards checks Sadler’s ribs.
  • 2:03 am: While washing up at Lockhart’s Coffee Rooms, Fred Smith hears groaning from outside and from an upstairs window he can see Sgt Edwards and Sadler, who is bent over holding his side and swearing. They are then approached by PC Frederick Hyde who also checks Sadler’s ribs. Seeming to recover upon the reassurance of the two policemen Sadler walks towards the Minories, later claiming that he thought he was heading towards Leman St and on to the Hospital.
  • 2:12 am: Great Northern Railway shunter Solomon Guthrie leads his horses through Swallow Gardens and sees nothing suspicious. He is followed through the arch by another shunter, named Barnes.
  • 2:13 am: Michael Redding, another Great Northern Railway shunter passes through Swallow Gardens with his two horses and sees nothing suspicious.
  • 2:14 am: Police Constable Thompson had started his shift at 10 pm and it was the first time out on his own. His beat was Mansell St, Leman St, Prescot St and Chamber St and it took fifteen to twenty minutes. At around 2:14 am he is in Chamber St approaching Swallow Gardens and hears footsteps walking in the opposite direction towards Mansell St.
  • 2:15 am: PC Thompson walks down Chamber St towards the three archways, noticing the time on the clock on the Tower. Turning into the first arch he can see the body of a woman lying in the roadway. Thompson shines his bullseye lantern upon her and notices the blood oozing from her throat. Her eyes briefly flicker and he blows on his whistle. Her body is lying on its left side, 79 feet from Royal Mint St and 42 feet from Chamber St and her head towards Chamber St.
  • 2:17 am: PC Hyde, who was 250 yards away in Royal Mint St, arrives turning his lamp on he sees Coles throat is cut and runs to fetch Dr Oxley in Dock St.
  • 2:18 am: PC George Elliott, on plainclothes duty outside Baron Rothschild’s Refinery on Royal Mint St, arrives at the murder scene. He has a quick look around and runs to Leman St Police Station to inform Inspector James Flanagan, who sends for Dr Bagster Phillips, Supt Arnold, Chief Inspector Swanson and Inspector Reid. Carman Frederick Clarke is taking a load of fish to Billingsgate Market when he passes under the arch. Asking PC Thompson if he has found a drunken woman, Thompson tells him the woman is dead and sends him for help. PC Benjamin Leeson, arrives from the direction of the Mint.
  • 2:45 am: PC Hyde returns with Dr Oxley, and the Doctor asks PC Thompson whether he has moved the victim’s head, to which he replies, “Yes.” The gathering carmen, among them “Jumbo” Fryday and the Knapton Brothers, are unable to pass through the arch and witness Dr Oxley probing Coles’ neck wound with his fingers.
  • 2:50 am: Inspector James Flanagan arrives to find Dr Oxley on the spot examining the body.
  • 3:00 am: Sadler returns to 8 White’s Row asking for Coles, and pleading with Guiver, who is sweeping the hallway, to let him into the kitchen. Deputy keeper Sarah Fleming is in her office and tells Sadler that she would be fined 5s if she let him stop in the kitchen. Sadler tells Fleming “Well, you are a very hardhearted woman,” to which Fleming replies, “I can’t help that. I must do my duty and you must go out.” Sadler is reluctant to leave and hangs around the folding doors. Fleming asks Guiver to put Sadler out and Sadler leaves on his own accord.
  • 3:15 am: Dr Phillips arrives at Swallow Gardens by cab. While Phillips is examining the body, Inspector Flanagan notices the old bonnet in the folds of the skirt.
  • 3:30 am: PC Arthur Sharpe sees Sadler staggering along the Whitechapel Rd opposite the London Hospital and, having received information of the murder, stops and searches him but finds nothing. Sharpe offers to help him cross the road to the hospital but Sadler refuses and carries on up the Whitechapel Road. Superintendent Arnold arrives at Swallow Gardens. Inspector Reid gives the order for the body to be removed by two constables on the ambulance to the mortuary at Eagle Place, Old Montague St.
  • 3:50 am: Inspector Flanagan and Supt Arnold make an examination of the archway. In an opening behind a pipe, four feet up on the wall Inspector Flanagan finds a piece of folded news-paper, The Daily News, dated Sunday, January 11, and within it is another piece of folded paper containing two shillings.
  • 4:05 to 4:15 am: Sadler enters a coffee shop at 19 Whitechapel Road explaining to manager Joseph Richards that he has no money but has wages owing to him. Sadler then produces some tobacco to exchange for a coffee but Richards refuses and turns him out.
  • 4:45 am: Sadler enters the Receiving Room at the London Hospital and is seen by night porter William Fewell. Sadler has a lacerated scalp and a small cut over his left eye. As the injuries are not deemed serious the Receiving Room nurse, Helen (Ellen) Cooper, tends to his wounds. Sadler is left to sleep for an hour and a half on a sofa near a gas stove until he is awakened by Fewell who gives Sadler a penny and tells him he must leave as he is going off duty.
  • 5:45 am: Chief Inspector Swanson and Inspector Moore arrive at Swallow Gardens and with Detectives search the area where the body was found and look for writing on the walls of the arch and the wooden hoarding. Swanson then gives the order for the blood to be washed away and the arch be opened to traffic, a sample of the blood being taken for analysis before it is washed away. All there is left for the curious to see is the rough mark of a cross cut into the hoarding by a Policeman where the deed was done.
  • 6:00 am: Sadler walks to the Victoria Home in Upper East Smithfield to beg unsuccessfully for a few halfpence. He apologizes to the Deputy Keeper, John Johnson for his behavior earlier that morning and leaves his bag in room 36.
  • 6:30 am: Charles Littlewood, a waiter at Stephen Longhurst’s coffee house, 73 Whitechapel Rd, serves Sadler a cup of cocoa. Sadler is refused a second cup as he is drunk. Littlewood notices that Sadler smells like he has been “in a Doctor’s shop”. Sadler reads a newspaper and talks to manager Stephen Longhurst.
  • 10:15 am: Duncan Campbell is standing by the fire in the hall at the Sailors Home, Wells St. Sadler sits next to him and tells Campbell that he has been out all night, been robbed and needs a drink. Sadler takes out a knife from his right-hand packet and sells it Campbell for a shilling and some tobacco. Sadler is also seen in the Sailors Home by Thomas Johnson, able seaman of the SS Mandalar.
  • 10:30 to 10:50 am: Sadler enters the Shipping Office on Tower Hill and cashes his £4 15s. 1d. wage check with deputy superintendent Edward Gerard Delfosse.
  • 11:00 am: Sadler returns to the Victoria Home at 40 Upper East Smithfield and stays there all day, leaving only to visit the Phoenix Public House twelve doors away. Duncan Campbell hears of the murder in the neighborhood and goes into the lavatory of the Sailor’s Home to inspect the knife. He notices the “salmon” coloring of the water when he soaks the knife in water for a minute in one of the clean basins. He puts the knife in his pocket and goes to his room to sleep.
  • 2:30 pm: Spitalfield’s Chambers lodger Samuel Harris is at work on Virginia Rd, Shoreditch, when he reads about the murder and that the victim had a bonnet pinned in the folds of her dress. He runs back to the lodging house and asks if anyone has seen Frances. Then he, Sarah Fleming and Florence Monk go to Leman St where they are taken by a detective to the Mortuary at Eagle Place where they identify Coles. Back at Leman St, Harris tells the police that he can identify her companion and accompanies Sgt John Don and PC Gill for the rest of the day searching around Whitechapel Rd, Commercial Rd and then finally home.
  • 3:30 pm: Duncan Campbell wakes up in his room at the Sailors Home and leaving through the Dock St entrance walks across the street to marine stores dealer Thomas Robinson who buys Sadler’s knife from Campbell for 6d. The agreement being Campbell is to buy back the knife on the Monday for 9d.

SATURDAY FEBRUARY 14, 1891:

  • 9:00 AM: Harris resumes the search with Sgt Don and PC Gill. They visit the Victoria Home, the Minories and the Docks.
  • 12:00 PM: At midday Harris finds Sadler half and half and drinking alone in the Phoenix, Upper East Smithfield. Harris does not say anything to Sadler in case he bolts but goes back outside and tells the waiting Detectives. Sadler is called outside and taken directly to Leman St Police Station. Upon his person is found a pipe, tobacco, an advance note, a postal order for 2s, several cards and memoranda. His kit bag, collected from The Fez contains spare clothing. Sadler is kept in a cold ante-room and, for the purpose of lineup, is made to change his clothing. The police keep his clothing for inspection. Sadler complains that the clothes he is given are cold and damp. Milliner’s assistant Peter Hawkes picks Sadler out of a lineup at Leman St as the man who accompanied Coles and stood waiting outside his shop window. Sadler spends the night at Leman St Police Station sleeping on a plank in his makeshift cell.

TUESDAY MARCH 3, 1891:

  • Sadler again appears at the Thames Police Court. He is discharged by the magistrate in consequence of the prosecution having been withdrawn. Sadler waits in gaoler Sgt Baker’s room, with his solicitor, to avoid any demonstration by the waiting crowd. Eventually, a cab draws up in the adjoining yard and Sadler, his solicitor and a Star reporter climb in and drive away. In Charles St, Sadler — a free man again — sticks his head out of the cab window and waves his hat to the crowd.

Sources:

Timeline adapted from “Tom Sadler ’48HRS‘” by J.G. Simons and Neil Bell, The Casebook Examiner, Issue 6, February 2011, pgs. 29-47

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