Rocca

The defendants are father and son, and the complaint charges Steinmetz, Jr., with having recklessly and negligently driven an automobile off the road and down an embankment, whereby one Marguerite L. Eocca, mother of William Eocca, was killed, she being at the time a passenger in the automobile and a guest of said driver. It is alleged that Steinmetz Sr. was the owner of the automobile and bought and kept it for the use and pleasure of his family, including said son; that said Steinmetz Jr. “was at all the times herein mentioned a careless and reckless person and careless and reckless driver of said automobile and the said D. H. Steinmetz knowing said D. H. Steinmetz Jr. to be such a careless and reckless person and careless and reckless driver of said automobile, negligently allowed and permitted said D. H. Steinmetz Jr. to drive said automobile; and that at and immediately prior to the time of the accident hereinafter referred to, defendant, J. H. Steinmetz Jr. was driving said automobile with the consent, knowledge and permission of defendant, D. H. Steinmetz, and was acting in furtherance of and not apart from the service and control of defendant, D. H. Steinmetz, and within…