15.  A  state  court  has  recently  em-
phasized this:  In  a  shipper's  action
for  damages  in  transit,  where  plain-
tiff affirmatively  alleged,  as  matter
on  which  its  cause  of  action  was
based,  that  a  bill  of  lading  was  is-
sued for  the  shipment  and  delivered
to  it,  which  was  denied  by  the  an-
swer, for  proof  of  issuance  of  the
UD  plainti£F    cannot    substitute    the


presumption  that  since  the  Carmack
Amendment  directs  that  a  bill  of
lading  will  be  issued  by  the  initial
carrier,  it  will  be  presumed  that  it
did  its  duty,  and  one  was  issued.
Cudahy  Packing  Co.  v.  C.  &  N.  W.
Ry.   (Mo.  1917),  196  S.  W.  406.
16.  McRary  v.  Southern  Ry.  Co.
(N.  C.  1917),  94  S.  E.  107.
