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AMERICAN AND BRITISH

CLAIMS ARBITRATION. Tribuna).
s Clain, no. 301

ROBERT E. BROWN

MEMORIAL
OF THE UNITED STATES

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Memorial of the United States in Support of the Claim.

This is a claim arising out of a denial of justice suffered by the late Robert E. Brown in the courts of the late South African Republic in a certain action wherein Robert E. Brown was plaintiff and Dr. W. J. Leyds, Secretary of State of the South African Republic, and A. A. J. C. Dieperink, Responsible Clerk at Doornkop, were defendants.

Robert E. Brown was born at the City of Philadelphia on the 31st day of May, 1865, and died at the City of Phoenix, in the now State of Arizona, on or about the 4th day of October, 1902;1 he was a citizen of the United States by birth and during his entire life continued to be an American citizen and never took any oath nor entered into any acknowledgment, compact or obligation disentitling him to the protection of the United States in respect of the claim hereinafter set forth. By his last will and testament, Robert E. Brown appointed his father, Lawrence Emanuel Brown, his executor and directed that his estate should be equally divided between his wife, Marion E. Brown, his father, Lawrence Emanuel Brown, and his mother, Martha E. Brown, all of whom are American citizens. The will of Robert E. Brown was duly proved in the office of the Registry of Wills of Philadelphia County and City on the 18th day of October, 1902.

The facts in connection with this claim briefly stated are as follows:

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