Q. I understood you to say that you were in the printing business?-A. Yes, sir. Q. Would it be any more difficult to counterfeit a ticket on lithograph plate than on plain white print paper?-A. I do not know that it would. Q. When one of said tickets was lightly folded would it remain folded, or would it be liable to spring open? (Objected to.) A. It would be liable to spring open, except it was creased very thoroughly, and even then it would probably spring open. Q. If another ticket were 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 incompetent and immaterial.) · A. I do not know; I never tried it; I cannot say. The probability is it would spring open and give a chance for the inside one to drop out; I never tried it. Q. Could you distinguish the said Republican ticket when folded with the names inside by sight? A. Yes, sir. Q. Could you do it by touch ?-A. Yes, sir. Q. Could you distinguish that Republican ticket from the Democratic ticket, both tickets being folded separately with the names inside?-A. I could. Mr. PEELLE: I object all the way through to all these questions and answers as immaterial and incompetent. Q. Could you distinguish that Republican ticket voted for Mr. Peelle from the National ticket voted at the same election, both being folded?—A. I could; yes, sir. Q. Could you distinguish said Republican ticket voted for Mr. Peelle from any ticket of like length and width, that was either on plain white print paper, writing paper, or book paper of the same thickness? (Objected to as incompetent and immaterial.) A. I could. Q. Could you distinguish the Democratic ticket voted at that election from the National ticket voted at that election, the tickets being folded?-A. No; I think not. Q. Could the inspector, and other election officers, tell by these plate tickets, even when folded with the names of the candidates on the inside, whether or not the person voting at said election was voting the Republican ticket?-A. I should think he could. Q. Could a person looking on at the polls at that election tell the Republican ticket when the voters handed them to the inspector and the inspector placed them in the ballotbox, supposing the tickets were carefully folded with the names of the candidates inside? (Objected to as incompetent and immaterial, because the witness cannot tell what other people could have seen.) A. Yes, sir. Q. What is the weight of a ream of plain white print paper, size of sheets being 25 by 38 inches?-A. About 30 pounds to the ream is the average size. Q. Do you know what was the value of that paper per ream, plain white print paper, at the time of the election referred to?-A. About $2. Q. What is the weight of a ream of plain white book paper of the same size?—A. About 50. Q. What was it worth per ream at the time of the election?-A. Fifty-pound was worth about $4 a ream. Q. What is the weight of a ream of lithograph plate, such as that upon which the Republican ticket was printed upon, 25 by 38 inches?-A. That I do not know. I have used very little of it since we have gotten out of the lithographing business. We have had no use for it in our business. Q. Do you know what the price of such paper is, generally, in the market?—A. Generally from 12 to 14 cents a pound. Q. This ticket that I have shown you, this Republican ticket which is made an exhibit, was that the ticket which was voted at your precinct by the Republicans?—A. I should think it was, sir, or one just like it. Cross-examination by Mr. PEELLE: Q. What is your politics?-A. I am a Democrat. Q. How long have you been a Democrat?-A. I cannot tell you. Q. Born that way?--A. Born that way; yes, sir. Q. Did you have any bet on the result of the Congressional election last fall?-A. I did after election day. The day after the election I bet one-half a box of cigars. Q. Did you bet on Mr. English?-A. I did. Q. Before the returns came in?-A. Yes, sir; before they came in. Q. Is there any difference between this Democratic and National ticket that you have been talking about in the paper?-A., Yes, sir; there is a little difference. Q. What is the difference?-A. The Democratic ticket is on a little bit better paper than the National ticket. Q. What kind of paper is that?-A. That is book paper. Q. Now take the Republican ticket and say what is the difference between that and the Democratic ticket.-A. The difference is, one is book paper and the other is plate paper. Q. The Republican ticket is plain white paper?-A. Yes, sir; plain white plate paper. Q. And the other is plain white book paper?-A. Yes, sir. Q. Still they are both plain white paper?-A. Yes, sir; one is "plate,” and the other is book." Q. Still they are both plain white paper. Is not this plate paper equally as plain white paper as the book paper is plain white paper?-A. No, sir; if a man would ask me for plain white paper I would never show him lithograph. Q. What would you show him?-A. Book paper. Q. You say that plate paper is not plain white paper?-A. It is plain white lithograph paper. Q. It is paper, is it not?-A. I suppose it is. Q. What is the color of it?-A. White. Q. Is it not plain white?-A. It is plain white lithograph. Q. Is it not plain white?-A. Yes, sir. Q. If it is paper, and its color is plain white, is it not plain white paper?-A. If a man would come in and ask me for plain white paper Q. I am not asking you about that. You say it is paper, and you say it is plain white in color. I ask you if that don't make plain white paper?-A. I suppose you would call it that, but nobody would ever inquire for it in that way. Q. You would call it plain white paper as much as you would the Democratic ticket, that is book paper, plain white?-A. That is plain white paper. Q. You would not designate that as plain white book paper?-A. You would call it plain white book paper. Q. The only difference is that one is plain white book paper and the other is plain white plate paper?-A. Yes, sir; there is a difference in the thickness, and in the grade, and in the quality. Q. Are there different qualities of book paper?-A. Yes, sir. Q. The Democratic ticket is heavier than the National?—A. Yes, sir. Q. Very nearly as much difference in the weight of those two as between the Republican and Democratic?-A. No, sir; I think not. Q. Did you ever have any experience in manufacturing paper?-A. No, sir. Q. Did you ever deal in paper as a dealer in paper?-A. No, sir; we buy a great deal. Q. All you know about paper is as you use it in your book publishing and binding business.-A. Yes, str; we buy a great deal of paper. Q. You said you could distinguish the tickets by sight and by touch.-A. Yes, sir. Q. How did you distinguish it by sight?-A. If I get near enough I can tell by the thickness of the paper and the quality of the paper. Q. You can distinguish the Republican from the Democratic ticket because it is on a little heavier paper?-A. A good deal heavier paper. Q. And no other way?-A. That is about all. Q. And that is the same difference you could tell in any paper; because of its thickness and quality?-A. Yes, sir. Q. Could you tell the difference between the National and Democratic tickets?—A. Not without I examined them beforehand. Q. Are they the same color?-A. They are not exactly the same color; one is a little whiter than the other. Q. You could tell those tickets by the color, couldn't you, readily ?-A. If I examined them before. Q. You see the difference between the color there of the two tickets? A. Yes, sir. Q. As to the Republican and Democratic tickets--is there any difference in the color of those two tickets?-A. Very little difference. Q. Less than there is between the other two?-A. About the same difference. Q. You say there is no more difference between the Democratic and Republican tickets in color than there is between the Democratic and National tickets in color. Look again. — A. Yes; there is a little more difference in color. Q. Then you could more readily distinguish the Democratic from the National by sight than you could the Republican from the Democratic by sight.-A. No, sir. Sometimes all the paper is not of the same color. Without I saw the inside of the Democratic and National tickets I could not say which was which. Q. You could not tell one from the other?-A. I could tell the Republican on account of its thickness. Q. Could you more readily distinguish the Democratic ticket from the National ticket than you could the Republican ticket from the Democratie ticket by the color ?—A. Yes, sir; provided I looked inside and saw what the ticket was. Q. I am speaking about the color of the ticket: the outside of the ticket that shows when the ballot is folded. Could you tell the difference between that Republican and Democratic ticket in any other way unless you could see the edge of the ticket and see which was the heaviest ?-A. No, sir; I could not. Q. Then there are different qualities of what you call plain white print paper.—A. Yes, sir. Q. You could tell the difference between heavy print paper and light print paper the same way if you could see the edges?-A. Yes, sir. Q. You say that is a lithograph there, the heading?-A. No, sir; I did not say any such thing. Q. You say it is engraved?-A. Yes, sir. Q. How do you know it is engraved?-A. I know it is engraved because there is no type made like that. The original one is engraved. I suppose this is an electrotype or stereotype of the engraving. Q. The reason you say it is engraved is because there is no type of that kind.-A. No, sir. Q. There is not anything in the head that makes you think it is engraved?-A. Yes, sir; that embellishing mark, that flourish down there, is not in type. Q. That is the reason you tell it?-A. Yes, sir. About the same reason that if your picture was on there you could not print it from type. Q. The only reason you say this is an engraving is because there is no such type printed?-A. My reason is there was a flourish on it. Q. Why?-A. Because that was engraved. Q. How do you know it was engraved?-A. Because it never was printed from type. Because there is no such type made. Q. Then it is your opinion that there is no type made like that?-A. No, sir. That has nothing to do with it. My opinion is that this is an engraving. Q. Is there any other way by which you can tell an engraved ticket from a printed ticket of that kind?-A. Certainly. Q. How do you tell it?-A. From the looks. Q. Is not the only thing in the looks that you know there is no such type?-A. No, sir. Q. If you can tell any other reasons I wish you would tell them.—A. I just explained it. Q. You said it was because you knew there was no such type.-A. That was one reason, and another reason was that that ticket was engraved. Anybody that would see it would know it was engraved. Q. How do you know it was engraved outside of the fact that you know there was no such type, if you can tell an engraving from a printing except from the fact of your knowlege of the different type?-A. I know from my knowledge of engraving that that ticket was engraved. Q. You know it was engraved?-A. Yes, sir. Q. Can you tell us why?-A. From the appearance of the head. Q. What is there in the appearance?—A. I have just explained that once. these flourishes and the general appearance of the head of the ticket. Q. If that were printed, how different would it be?-A. This is printed. It is in Q. I thought you said it was engraved?—A. Certainly, the head must be engraved, but it was printed from that. Q. What difference would there be between that if it had been originally printed from type?-A. The difference is in the appearance. Q. What is there in the appearance?-A. I have just explained that. Q. I have not heard it.-A. I told you it was on account of the flourishes that are on there. Q. What difference is there in those flourishes from what there would be if they had been printed that way from type?—A. It could not be printed from type, because there is no such type made. That is one reason, and another reason is that I am positive it was engraved. Q. You said this ticket would spring open if it were folded lightly?-A. Yes, sir. Q. Would not the Democratie ticket do the same thing?-A. No, sir; not exactly. Q. Suppose you take the Democratic and Republican tickets when they were folded with the crease like that. [Illustrating.] Is there any more danger of that ticket springing than the Democratic ticket similarly folded?-A. Yes, sir; I think there is. Except you fold it that way. [Illustrating.] Then it would hold its place. Q. I will ask you if the only difference in the spring of these tickets is not in consequence of the quality of the paper?-A. In the thickness and quality? Q. In the thickness and quality, I mean.-A. Yes, sir. Re-examination by Mr. WILSON: Q. Are you engaged in the printing business?-A. Yes, sir. Q. How long have you been in that business?-A. About 24 or 25 years. Q. Do you do much printing?-A. Yes, sir. Q. Do you do any engraving?-A. No, sir. Q. Do you have it done?-A. Sometimes. Q. Do you ever do any lithographing? A. Yes, sir. Q. Yourself?-A. I have it done in our establishment. Q. Mr. Peelle asked you if this was not plain white, and if it was not paper? Is it not what you call cardboard paper in one sense? (Objected to as incompetent.) A. Outside of experts, the majority of people would call that ticket cardboard. Q. That Republican ticket?-A. Yes, sir. Q. You answer as an expert? (Objected to.) A. Well, I do not know about that. Q. I will ask you whether or not that material upon which that Republican ticket is printed has not an ascertained meaning and an ascertained name in your business?—A. Yes, sir, Q. Is it called in that business, as it is technically named, plain white paper? · (Objected to as leading.) A. No, sir. Q. What is it?-A. Plate paper. Q. I will ask you what you call plain white paper in your business? (Objected to.) A. Book paper or writing paper. Q. That is what you mean by plain white paper?-A. Yes, sir. Re cross-examination by Mr. PEELLE: Q. That is what you mean by plain white paper, book paper, writing paper, and print paper? A. Yes, sir. JOHN C. SHOEMAKER, being first duly sworn, testified as follows: Direct examination by Mr. WILSON, attorney for Mr. English. JOHN CAILON. Question. Please state your name, age, and residence.—Answer. John C. Shoemaker; age, 57; residence, Indianapolis. Q. How long have you resided in Indiana?-A. All my life. Q. Have you held any official position; if so, what?-A. I was county treasurer and county auditor; served in both branches of the legislature, and auditor of State. Q. Were you in the city of Indianapolis at the time of the Congressional election held November 7, 1882?-A. I was. Q. Did you attend at any precinct on that day?-A. I was at several of the precincts during the day. Q. Who were the candidates for Congress in this seventh Congressional district on the Democratic ticket, and on the Republican ticket, and on the National or Greenback ticket?-A. Mr. English was the Democratic candidate, Mr. Peelle the Republican, and Mr. Medkirk was the National candidate. Q. Did you see the Republican ticket voted for Stanton J. Peelle for Congress at that election in the city of Indianapolis?-A. Yes, sir. Q. I call your attention to the ticket which has been made an exhibit to the deposition of Mr. De Vay, Exhibit B, and ask you whether or not that is the ticket?-A. Yes, sir; it was a ticket similar to that. Q. You saw the National ticket and the Democratic ticket voted at that same election? A. Yes, sir. Q. I call your attention to Exhibit D, headed National ticket, which has been made an exhibit to Mr. De Vay's deposition, and ask you if that is the National ticket?-A. Yes, sir; I think so. Q. I ask you the same question as to Exhibit C of Mr. De Vay's testimony, headed Democratic ticket?-A. I should say it was. Q. I will ask you now whether the Republican ticket voted at that election had any distinguishing mark or other embellishment except the name of the candidates and the offices for which they were running? (Objected to as immaterial and incompetent; that the ticket is the best evidence.) A. The heading I regarded as a distinguishing mark. Q. Can you describe what that distinguishing mark or embellishment was or is?—A. I do not know hardly what you want by the question. Q. Wherein does it differ from ordinary type used in printing? (Objected to as incompetent and immaterial.) A. The other tickets are plain type, and the Republican ticket has a figure in the head; and, in my judgment, an engraved head. Q. You say that that is an engraved head?—A. That would be my judgment. That is printed from an engraving. Q. Does the material upon which the ticket is printed designate it?-A. Oh, yes, sir; I think so. Q. Do you call that plain white paper upon which that Republican ticket is printed? (Objected to as leading.) A. Well, if a person was to ask me for plain white paper, I should not think of presenting him with that. (Answer objected to as not responsive to the question.) Q. When lightly folded would that Republican ticket remain folded or spring open ?— A. Spring open. Q. If another ticket were placed inside of that Republican ticket and then folded, and the tickets thus folded together dropped into the ballot-box, would the tickets be liable to spring open and separate so as to release the inclosed ticket and make two ballots? (Objected to as immaterial and incompetent and leading, and as assuming that tickets were folded one within another as indicated by the question.) A. Yes, sir; I think they would. Q. Could you, by sight, distinguish that Republican ticket when folded with the names inside from one printed on what you understand to be plain white paper? (Objected to as immaterial and leading.) A. Yes, sir. Under certain conditions I could, and under certain other conditions I could not. Standing near a poll and seeing them used I could. I could not do it at a great distance or under unfavorable circumstances, but under anything like favorable circumstances I could tell them apart. Q. Could you by touching it or handling it? A. Yes, sir; I could. Q. Could you by sight when you got a chance to see it plainly folded?-A. Why, I could if it was folded in the ordinary way like tickets are folded around the polls. I could tell it from the other every time under anything like favorable conditions, mainly from its bulk; and if it is in order I could give the reason. Q. At the polls, looking on and interested in the election and trying to ascertain what parties the voters belonged to, could you tell what ticket was being voted or what party the voter belonged to if he was voting this ticket?-A. Yes, sir. Standing at the poll, as near as from me to Mr. English, and seeing tickets handed in, I do not think I would miss it once in twenty times. Q. That distance between you and Mr. English is about four feet.-A. Yes, sir; as near as an ordinary challenger would stand. My method of telling it would be mainly from its bulk. The ticket is considerably more than twice as bulky as either of these other tickets; and tickets as they are folded ordinarily about elections are folded into eight folds-eight times, presenting eight thicknesses. That would make this ticket from eight to ten times thicker than the other ticket, because each piece of it is more than as thick again, and when they are brought together it makes the whole of it from eight to ten times thicker. That is the way I have noticed them-by their clumsy, bulky character. A voter going to the polls, if he held one end, as they ordinarily do, the other end would spring open and show the thickness. I watched them vote, and I think I could tell them every time. I did not do it from the color, because I don't think anybody, unless it was a very close observer and had sharp eyes, could do that. To a person feeling them there cannot be any question about that, because of the stiff, harsh character of them. In taking hold of them there is more resistance than there is in the other, and you can tell by the thickness. Q. Did you ever know such material to be used for tickets at any election? (Objected to as incompetent.) A. Never before, that I remember of. Q. Could you distingush the Democratic ticket voted at that election from the National ticket, both being folded with the names inside? (Objected to as incompetent and irrelevant.) A. I don't think I could. I did not try. I don't hardly think I could, because there |