A. Yes, sir. Q. What is it called at the manufactory where it is made? (Objected to as incompetent.) A. Plate paper. Q. Do you know what it is called in the catalogue issued by the principal dealers? (Objected to as incompetent and immaterial.) A. Plate paper. Q. What do you call it in your bills of invoice and on your books? (Objected to as immaterial.) A. Plate paper. Q. Did you sell any of this plate paper to the Journal Publishing Company before the said election? (Objected to as immaterial.) A. I did. Q. In making the entry of the sale on your book did you call it writing paper, print paper, book paper, plain white paper, or plate? (Objected to as immaterial.) A. It was charged and billed as plate paper. Q. What is such material generally sold for? (Objected to as immaterial.) A. It is principally used for lithographic work. Q. And it is generally sold for that?-A. Yes, sir. Q. Did you make an entry as to the weight of this paper that you sold to the Journal Company? (Objected to as immaterial.) A. I did. Q. What was that weight?-A. One hundred pounds. Q. What was the number of sheets you sold, and what was the price?-A. Six hundred and twenty-five sheets, and the price was $18.20, if I remember correctly. Q. Eighteen dollars and twenty cents for what?-A. Six hundred and twenty-five sheets. Q. Do you do a lithographing business?-A. I do. Q. Do you ever sell such material as this Republican ticket is printed on as plain white writing paper, or as plain white print paper, or as plain white book paper? (Objected to as immaterial.) A. I do not. Q. Do you ever sell it as plain white paper at all, or do you sell it as plate paper? (Objected to as leading and immaterial.) A. We sell it as plate paper. A. Does a mill that makes print paper ever make this lithographic plate or this plate paper? (Objected to as immaterial.) A. I think not. Q. In your long experience did you ever know plate paper to be used for election tickets before? (Objected to as immaterial.) A. Never. Q. What is the weight, if you know, of a ream of plain white print paper, size of sheets 25 by 38, and what is it worth per ream, or what was it worth per ream at the time of said election? (Objected to as incompetent.) A. The standard weight is 30 pounds; worth about $2 per ream. Q. What is the weight of a ream of plain white book paper of the same size? (Objected to as incompetent and immaterial.) A. The standard is 45 pounds. Q. Do you recollect what it was worth at the time of the election?-A. Worth about $3.80, according to the quality. I will qualify that a little. Book paper might run from $3.80 to $4.50. Q. What is the weight of a ream of plate paper such as this Republican ticket that you have looked at is printed upon?-A. You mean of a relative size? Q. Yes, sir; 25 by 38. (Objected to as immaterial.) A. About 100 pounds. Q. What was it worth per ream at the time of the election, if you know? (Objected to as immaterial.) A. About $14 or $14.50. That would depend upon how much profit a man wanted to make. Q. If one of your customers should buy for election tickets this plate paper at $14 to $14.50 per ream, and he could get good plain white book paper at the price you have named per ream, and plain white print paper at the price you have named per ream, would not you think that he was either ignorant or had some design in it? (Objected to as incompetent and irrelevant, and because it seeks the opinion of the witness rather than the fact.) A. If I knew he was going to use it for tickets I should infer that he either had a design or wanted to make a pretty big bill against the central committee. One of the two. Q. Would it be any more difficult to counterfeit a ticket on this plate paper than on plain white print paper?-A. It would not be if you could get the paper. Q. When one of these Republican tickets was lightly folded, would it remain folded or spring open? (Objected to for the reason that it assumes that the ticket was lightly folded when voted.) A. It would spring open if the folds had not been creased. Q. If another ticket was folded inside this ticket and thus folded, said tickets were dropped in the ballot-box, would this ticket be likely to spring open and separate so as to release the inclosed ticket and make two ballots? (Objected to as immaterial and incompetent and leading, because it assumes that there were tickets folded inside.) A. You say thus folded?" Q. Folded as you say, lightly folded.-A. It would spring open. Q. Would not tickets so folded and made upon the material that this Republican ticket is made be more apt to spring open than tickets made of the material upon which the Democratic and National tickets are made of and voted? (Objected to as immaterial.) A. It would. Q. Could you distinguish said Republican ticket when folded with the names inside, either by sight or touch ?-A. I could. Q. Could you distinguish said Republican ticket voted for Stanton J. Peelle from the Democratic ticket voted at said election, said tickets being separately folded with the names inside? (Objected to as immaterial.) A. If I could get a chance to see each of them I could. Q. Could you distinguish it by the touch?—A. Yes, sir; by the feeling. You said "sight" in your question. Q. Could you distinguish them by sight if you could get to see them?-A. I could if I could see the end of the tickets, but I could not to see the back of the ticket. If a man would take a ticket up and hold it between his hand in that shape [illustrating], and let me see the back, I would have my doubts about whether I could do it or not; unless I would judge from the stiffness of it. Q. Could you distinguish this Republican ticket from the National ticket?—A. I could. Q. Could the inspector and other election officers tell by these plate tickets when folded with the names inside whether or not the person voting it at said election was voting the Republican ticket? (Objected to as immaterial and leading, and because the witness cannot tell what the election board would know or think.) A. I believe I could. Q. Could persons looking on at the polls tell the same? (Objected to for the reason that the witness cannot tell what the populace would say.) A. That I cannot answer. It would depend upon what they were looking at, I sup pose. Cross-examination by Mr. PEELLE: Q. You are a Democrat, I believe, in politics?—A. I am, sir. Q. If I remember rightly you had no bet on the last election at all as to the result between Mr. English and myself?-A. No, sir; I never bet on elections. Q. I will hand you the Democratic and National tickets, which have been introduced as a part of the evidence of Mr. De Vay; and I will ask you to state if there is any dif ference between the kind of paper that these two tickets are printed on?—A. Well, I think there is a slight difference. Q. I will ask you to state what that difference is.-A. One is a little better grade of book paper than the other. Q. Are they both printed on what is known as book paper?-A. They are. Q. I now hand you the Democratic and Republican tickets identified before, and ask you to state the difference between those two tickets.-A. One is printed on book paper and the other is printed on plate paper. Q. Are they not both printed on plain white paper?-A. They are; so far as white goes, if you do not qualify. Q. The only difference being one is what is known as "book" and the other is what is known as "plate paper"?—A. Yes, sir. Q. You stated something about the heading of that ticket.-A. I said it was engraved; I believe it to be. Q. Do you know whether it is engraved or not; can you answer whether or not it is?— A. So far as my judgment goes it is engraved. Q. If it should be printed you would be mistaken.-A. It has got to be printed after it is engraved; the original has to be engraved first before you can print; it is not worked from type; there is no type can be set in that shape. Q. You say you sold some paper of this kind to the Indianapolis Journal Company?— A. I did. Q. When?-A. The day before the election. Q. Is that the same kind of paper?-A. Yes, sir. Q. Was the paper you sold them used in printing tickets?-A. That I could not say. Q. Did the Indianapolis Journal Publishing Company return you any paper of that kind?-A. Not that I know of. They may have done so quite a while afterwards, but not at the time. They did not return that paper. Q. I will ask you if the Indianapolis Journal Publishing Company did not borrow some paper of you just before the election?—A. That I could not state. We are not in the habit of borrowing or loaning paper. We sell each other paper and bill it to each other. The paper that I sold them was sold to them and billed to them and charged to them. Q. You say you sold them 625 sheets?-A. Yes, sir. Q. The day before the election?-A. Yes, sir. Q. You do not know whether 625 sheets were returned to you afterwards or not?-A. I have no knowledge of it. Q. You cannot say whether these tickets are printed on the same paper you sold them or not.-A. The identical paper? Q. Yes, sir.-A. No, sir; I cannot. I did not stand over the press and see it done. Q. I hand you what purports to be the Democratic ticket voted in Hancock County at the last election. Will you please examine that paper, and state what kind of paper it is, or what difference, if any, there is between that and the Republican ticket voted in this city?-A. I call that an extra heavy “book." Q. What is "plate paper" used for?-A. Principally for lithographic work. Q. Can you not lithograph on the kind of paper you now have in your hand?-A. I can. Q. I will ask you if you cannot lithograph on that kind of paper equally as well as you can on this kind of paper upon which the Republican ticket is printed?-A. I cannot. Q. What is the difference?-A. The difference in the thickness of the paper. Q. I understood you to say you could not distinguish this Republican ticket from either the Democratic or National ticket unless you could see the edges of the tickets.-A. That was my answer. Q. I will ask you to state to the notary whether or not you can distinguish the Democratic and National ticket, which I now hand you and which has been made part of the deposition of Mr. De Vay, by feeling them?-A. Having examined the tickets just recently, at this time I could. Q. State if the Democratic ticket is not smoother paper than the National ticket?— A. I think not, so far as the finish is concerned. It is lighter. Q. What is lighter?-A. The National ticket is lighter than the Democratic. Q. Is not the Democratic ticket a finer finish than the National ticket?-A. Not that I can feel. Q. Look at it and see if you do not discern a finer finish on the Democratic ticket than on the National ticket?-A. I see a whiter paper. Q. State if it is not as difficult to detect the Republican ticket by feeling from the Democratic ticket, and the National ticket, as it is to detect the Democratic ticket from the National ticket by feeling?-A. It is not. Q. What is the difference?-A. In the thickness of the paper. Q. I am not speaking of the thickness of the paper. I am speaking about the feeling of the surface of the paper.-A. No, sir. It is not quite so difficult. Q. What is the difference?—A. The difference is that the plate paper is a little finer finish than either of those, and smoother. Q. Is there any finer finish on the Republican ticket than on the Democratic ticket that you hold in your hand?—A. Yes, sir; I think there is. Q. What is the difference in the finish?-A. They come through the calender Q. (Interrupting.) Do not they both pass through the same calender?—A. Yes, sir; but the plate paper passes through oftener. Q. Is not that for the purpose of making it more compact, more than for the purpose of putting a fine finish on it?-A. No, sir; it is not. It is for putting additional finish on it. Q. I will ask you to state when the Republican ticket is folded with a crease, as tickets usually are when voted, if it is not just as liable to remain folded as the Democratic ticket similarly folded?-A. Not quite so much so. Although creased, there is more or less elasticity in this paper that would open it to a certain extent. You can test it yourself. Q. I will ask you to state now if the only difference in the spring of the tickets is not in consequence of the heft of the ticket alone.-A. I think it is. Q. Then there is no particular quality in the paper to make it spring, other than its weight? A. I think not. Q. It is not bristol-board?-A. No, sir. Q. It is not card-board?-A. No, sir. Q. It is paper?-A. Yes, sir. Q. And the color is plain white?-A. Plate paper; yes, sir. Q. Do you know of anybody that was misled in voting in consequence of that ticket?— A. How do you mean? Q. Voted differently from what they would if the ticket had been printed on the same quality of paper that the Democratic ticket was printed on.-A. Was misled by it? Q. Yes, sir. Did anybody vote differently in consequence of this Republican ticket being printed on this kind of paper, that you know of?-A. I know of one instance. Q. What was the instance? Explain it.-A. It was this way: It was a colored man. I was at the polls asking him to vote the Democratic ticket, and he agreed to do so and he picked the ticket up and went up to the polls and returned, saying that they knew he was going to vote the Democratic ticket and he would not do it. Q. That is the only instance, is it?-A. That is the only one I have any knowledge of. Q. You do not know of anybody that was misled, or voted differently from what he would have voted, other than that?-A. No, sir. Q. And that is what he told you?-A. Yes, sir. Q. Do you know the name of the colored man?-A. I know the man when I see him. I do not know his name. Q. Do you know where he stops?-A. He was working around. I don't know where he lives. Q. Have you seen him since?-A. I saw him once, and only once. Q. Do you know where he was living at that time?-A. I do not. Q. You cannot give his name?-A. I cannot. Q. What precinct was that in?-A. It was in the fifth ward; I do not know which precinct it was. Q. On what streets?-A. On the corner of First and Illinois. Q. Have you made any examination of the folding of these different tickets, as to the spring there is in them?-A. I have not. Q. You have not tested it at all?-A. No, sir. Re-examination by Mr. WILSON: Q. I understood you to say that the Democratic and National tickets shown you were both printed on book paper.-A. Yes, sir. Q. And that it was plain white paper.-A. Yes, sir. Q. You were asked if you could distinguish the difference here, on an inspection, between the Democratic and National tickets. Could you tell the difference, looking on at the election, between the Democratic and National ticket, as voted on that day?-A. I could not. Q. Mr. Peelle asked you if this Republican ticket was not printed on plain white paIs it not true that, in that sense, card-board is plain white paper?-A. Certainly. WM. B. BURFORD. per. JOHN CARLON, being first duly sworn, testified as follows: Q. How long have you lived here?-A. Nineteen years. My age is 44. Q. How long have you been in that business?-A. I have been in the printing business about 24 or 25 years. Q. Were you in the city of Indianapolis at the time of the Congressional election on November 7, 1882?--A. Yes, sir. Q. Were you at any voting precinct upon that day?-A. Yes; I was in the eleventh ward, at one of the precincts there-east of Meridian street. I forget the number of the precinct. Q. Did you see the Democratic, Republican, and National tickets voted at that election?-A. I did. Q. Who were the candidates for Congress on the Democratic and Republican tickets?— A. Mr. English on the Democratic, and Mr. Peelle on the Republican. Q. You say you saw those tickets?-A. Yes, sir. Q. I show the ticket that is made a part of the testimony of Mr. DeVay and marked Exhibit B, headed Republican Ticket. Is that the Republican ticket that was voted that day?-A. I judge so. Q. Was there, and is there, any figure, embellishment, or distinguishing mark at the head of that Republican ticket, or elsewhere, to designate it? (Objected to as incompetent, for the reason that the ticket will show for itself.) A. It has an engraved head. Q. I will show you also the ticket marked Exhibit C, which was made a part of the deposition of Mr. DeVay this morning, and ask you if that is the ticket that was voted by the Democrats at that same election?-A. Yes, sir. Q. Also the ticket marked Exhibit D, to the deposition of Mr. DeVay, headed National Ticket. Is that the ticket that was used and voted by the Nationals on that day?-A. I judge so. Q. Was the Republican ticket, voted on that day, on plain white paper? (Objected to as leading and incompetent.) A. It was on plain white plate paper. Q. Was it on plain white writing paper?-A. No, sir. Q. Was it upon white book paper?-A. No, sir. Mr. PEELLE. I want it understood that I am objecting all the time to each of these questions as incompetent and for the reason that the ticket must speak for itself. 、 Q. Was it plain white print paper? (Objected to for the same reasons.) A. No, sir. Q. What do you say was the material on which that Republican ticket was printed?— A. It is called "lithograph plate" paper. Q. Is that a kind of material known in the trade as either print, writing, or book paper? (Objected to as immaterial.) A. No, sir. Q. Do you buy it or sell it as either print, writing, or book paper?—A. No, sir. Q. If a man would come to your store and ask to buy plain white paper, would you show him such material as that upon which the Republican ticket was printed? (Objected to as incompetent and immaterial.) A. No. I would not. Q. Do you know what that material is called, that material upon which the Republican ticket was printed, by the manufacturers of it?-A. It is called lithograph plate paper. Q. What is it called in the printed catalogue issued by the principal dealers in such goods? (Objected to as immaterial.) A. It is called plate paper. Q. What do you call it in your invoice bills and books?-A. Plate. Q. Does a mill that makes print paper ever make this lithograph plate? (Objected to as immaterial.) A. I think not, sir. Q. Is this lithograph plate manufactured and sold for general use, or for a limited and specific use? (Objected to as immaterial.) A. It is generally sold for lithograph work. Q. In your long experience did you ever know lithographic plate to be used for election tickets? (Objected to as immaterial.) A. No, sir. I never did before. Q. Do you sell paper?-A. No; that is, not for trade. Of course we sell it to customers when we print books and such as that. Q. Is lithograph plate, such as the Republican ticket is printed on, made in the same way as either writing paper or print paper, if you know? (Objected to.) A. I do not really know. |