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All the ballots cast at said election except those from the 2d precinct of the 12th ward of the city of Indianapolis, as returned by the several officers of said election, passed through my bands, and according to the count made by me, allowing two hun dred and ninety votes as returned by the election officers of the 2d precinct of the 12th ward of the city of Indianapolis, Mr. Peelle received twelve thousand nine hundred and seventy-four votes, and allowing one hundred and ninety-two votes as returned from the said 12th ward, Mr. English received twelve thousand two hundred and seven votes, making a majority for Mr. Peelle of seven hundred sixty-seven votes as cast in Marion County, Indiana.

NORMAN S. BYRAM.

(Indorsed :) Exhibit No. 1 to deposition of N. S. Byram, Nov. 22, '83.

By agreement of all parties the further taking of these depositions was adjourned until Saturday, November 24, 1883.

The parties met pursuant to adjournment.

SATURDAY, November 24, 1883.

E. W. HALFORD, being first duly sworn, testified as follows:

Direct examination by Mr. PEELLE:

Q. State your name, age, and residence.-A. E. W. Halford; age, 40; residence, Indianapolis, Indiana. Q. State your business.-A. I am managing editor of the Indianapolis Daily Journal. Q. That is regarded as the leading Republican paper in the city, is it not?-A. I suppose it may be so taken as one of the leaders.

Q. How long have you been in journalism?-A. About 20 years.

Q. Were you ever in a job printing establishment?-A. Yes, sir.

Q. How long were you connected with a job printing establishment?-A. I have been in the printing business ever since I was 13 years old.

Q. Been in the job printing business?-A. In the job and printing business up until the time I went on the Journal, about 20 years ago.

Q. Are you familiar with, and have you haudled the different kinds of paper used in book printing?-A. I was at that time; I had charge of a job office for some time. Q. I hand you a ticket, headed " Republicau ticket," and marked Exhibit No. 1 to the deposition of J. G. Sexton; and I will ask you to take that and examine it, and state if you know what kind of paper that ticket is printed upon ?—A. I should say that was a heavy book paper.

Q. What grade of book paper would you call that?-A. I would hardly know now, because it has been a long time since I handled book paper. I would not know just what grade.

Q. By number can you tell?-A. I cannot tell that.

Q. It is a heavy grade of book paper?-A. Yes, sir.

Q. An unusually heavy grade f—A. It is an unusually heavy grade for ordinary printing.

Q. Have you used that kind of paper at any time in your business in the job printing business?-A. I expect I have; it seems to me I have, but I cannot recollect any particular job in which it has been used.

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Q. I hand you a ticket headed Democratic ticket," and marked Exhibit No. 2 to the deposition of James C. Yohn. Please examine that, and state what kind of paper that ticket is printed on -A. A lighter grade of likely the same paper.

Q. Would you call it book-paper?-A. It seems to me to have a calendered surface. QIs that paper such as is used in printing books?-A. I should think that paper would be used in printing books, but not a very good quality of book-paper.

Q. Examine the heading of that ticket and notice how the type are run together in the Democratic ticket in the words Democratic ticket; I will ask you to state if that is or is not an engraving. -A. I should think that was a cut.

Q. You mean a wood-cut -A. Well, it might be a cut, and then electrotyped from a wood-cut; I should consider it not to be type.

Q. It is printed from a cut?-A. I should think it would be; it looks to me like the same thing.

Q. Would you say the same thing of the Republican ticket?—A. Yes, sir; that is

a cut.

Q. Are you familiar with the different grades of plate paper, eastern and western plate-papers-A. No, sir.

Cross-examination by Mr. WILSON:

Q. You are not familiar with plate papers?-A. No, sir.

Q. Do you know when the use of plate papers came in vogue?-A. No; I could not say.

Q. It has been since you quit the jobbing business?-A. We did not have much of it when I was in the jobbing business.

Q. When did you quit thể jobbing business?-A. About in 1862 or 1863; I am not certain about that date exactly; Mr. Baden was running the establishment then. Q. You do not know the difference between book and plate, do you?-A. Not technically; no, sir.

Q. Might not that Republican ticket be plate paper then?-A. I could only answer that by saying that if there is any difference between book and plate-paper, I should think this was book paper, that is so far as my knowledge of paper is concerned.

Q. Would you call that ordinary book paper, or is it such book paper as is used in printing ordinary books?-A. It seems to me I have handled books printed on paper as heavy as that.

Q. Could you name any books printed on paper as heavy as that?-A. These fine gift books as I see them; it seems to me they are as heavy as that is.

Q. Then it is gift books and rare books, in your estimation, that are printed on that?-A. I should not consider that a paper.

Q. That is in ordinary use?-A. That is in ordinary use for printing books and pamphlets; it is a lighter grade of paper.

Q. I call your attention to the specimen marked Exhibit No. 4 to the cross-examination of J. G. Sexton, and I will ask you what is that material?—A. That appears to me to be a very light quality of what we call bristol board.

Q. I call your attention to Exhibit No. 1 on the cross-examination of Frank H. Smith, and I will ask you what that is?-A. I should say it was the same thing, practically.

Q. I call your attention to Exhibit U to the cross-examination of Mr. Salisbury, and I will ask you what that is?—A. I should think they were all about the same grade. Q. Bristol board?-A. A light quality of what we call in printing bristol board. Q. I hand you Exhibit No. 5 to the cross-examination of Mr. Sexton. What is that-A. That is probably a fine quality of paper or bristol board; I could not tell. That is very light; I think it is bristol-board.

Q. I call your attention to Exhibit No. 6 to the deposition of W. O. Anderson, and I will ask you what is that material?-A. Paper.

Q. What sort of paper?-A. Book paper.

Q. I call your attention to Exhibit B to the deposition of Mr. Wing. What is that?-A. That is paper.

Q. What sort -A. What I wonld call book paper.

Q. What do you call paper; what do you mean by that?-A. I do not know hardly how to explain that.

Q. What is paper?-A. I cannot give you the constituent elements of it.

Re examination by Mr. PEELLE:

Q. It is not bristol board or card-board ?—A. I cannot tell you how it was made. I have seen it made, but I do not know what the constituent elements of it are—whether wood. straw, or rags.

Q. You judge by what it is made ont of; you say it was put through a given process, and made out of rags, wood, and straw, and, if so, you would come to the conclusion it was paper?-A. No; I do not know that I would.

Q. Let us hear how you would judge?—A. I judge by the feeling or looks of it. That looks to me like paper.

Q. Is that white?-A. That is not very white. It is intended for white paper, I presume. It is not a very good color.

Recross-examination by Mr. WILSON:

Q. I call your attention to Exhibit No. 7 to the deposition of Mr. Anderson, and I will ask you what that is?-A. That is paper.

Q. What sort -A. Book paper for fly leaves, and so forth, in binding, I should think. It has been a good many years since I handled paper.

Q. I call your attention to Exhibit No. 1 to the cross-examination of A. G. Porter, and I will ask you what is the material ont of which that is made?-A. I would not like to answer that. I could not tell. I do not think anybody, unless he was very expert, could tell what that was. The surface of the back there looks to me like paper, but it does not have the appearance of bristol board, and I cannot tell what there is inside.

Q. Suppose that is made up of sheets of Republican tickets, one placed on top of the other, what would you call it then?-A. I would say it was made up of paper, if it was made of those Republican tickets. I should say it was a block of paper. Q. Do you know how card-board is made?—A. No, sir; I do not.

Q. Do you answer that a thing is bristol board simply because of its thickness ?— A. No, sir.

Q. Why-A. The surface appears different to the look and to the touch to me.

Q. What is the difference in the surface?-A. You can see there. It has a kind of a macerated appearance that card-board has not.

Q. Referring now to Exhibit No. 5 to the cross-examination of Mr. Sexton, what would you call that?-A. That is what I would call a light grade of bristol board, such as calling cards are printed on. That would just be my impression.

Q. When you cut it up into cards for visiting purposes you call it calling cards?— A. I used the term bristol board. We used that term in printing for calling cards, and light, tine work of that character.

Q. Is it not true that there are bristol boards a good deal thinner than certain qualities of book paper?-A. I should say so, but I do not know; that would be my impression that there is paper heavier than some grades of bristol board.

Q. Do you know the average weight of ordinary news printing paper, ordinary size, sized 25 by 38, such as the Indianapolis Journal is printed on ?-A. We print on a very light grade of paper, an unusually light grade.

Q. Is it not true that the Sentinel prints on a lighter grade than the Journal?-A. I do not know: I have not handled the Sentinel enough to judge of it. My judgment would be that we have printed upon a lighter grade than the Sentinel.

Q. Is it not true that the News prints on a lighter grade than the Journal or Sentinel?-A. I should think it is.

Q. What is the ordinary weight per ream, 480 sheets, sized 25 by 38 inches?—A. I do not know, but to jump at it I should say in the neighborhood of 40 or 45 pounds. Q. What would you say was the weight of the material upon which that Republican ticket was printed, size 25 by 38, per ream?-A. I should say 70 pounds, probably; I do not know.

Q. Would it not be a good deal more than 70 pounds?-A. I am just estimating now; I should think possibly it might be double the weight of the Democratic ticket; I do not think it is more than that, if so much; that is just the way it feels.

Q. What do you say from the external appearance of that Exhibit No. 1 on the crossexamination of A. G. Porter as to whether or not the material upon the outside is the same as that upon which the Republican ticket is printed?-A. I judge from the appearance of this that it was pasted on, and there was something there, underneath that, that interfered with the original appearance of the paper as it looks to me upon the back there.

Q. You mean in color?-A. No, sir; the texture. I do not know whether it was that or not.

Q. Do you think it has the same look at the front of the ticket and the back -A. I should judge that it has; I can only tell by the surface; it looks to me more like the face of the ticket than the back.

Q. You say that that Democratic ticket is a lighter grade of book paper. Look at it again and see if you think that may not be a grade of newspaper?—A. Yes, sir; it may be. It would properly go into the grade of newspaper, as experts would determine it, but I judge that grade of paper is very frequently used for printing books and pamphlets.

Q. A very inferior quality of book?-A. Yes, sir; it is not a very good calendered surface for book.

Q. It may be newspaper?-A. Yes, sir; pretty good newspaper if it is.

Q. You spoke of that Republican ticket being sized; do you say it is sized and calendered?-A. Sized and calendered; that is as much as I know about that.

Q. You do not know anything about the manufacture of paper, or the process A. No, sir; but as to the surface of it.

Re-examination by Mr. PEElle:

Q. This block of supposed paper marked Exhibit No. 1 to the cross-examination of A. G. Porter, which has been handed to you, I will ask you to examine and state how many tickets have been pasted together to constitute that block?-A. Is it to be presumed that these are all tickets?

Q. Yes, sir.-A. That is the assumption?

Q. Yes, sir.-A. I cannot give any reasonable estimate hardly about that. That has undoubtedly been in a press.

Q. Can you get at the number of tickets at the end?-A. I do not think I can. It seems to me like there was 30 or 40 put together.

Q. Just look at the other end, and see if you can count them. Are there as many as ten?-A. If that is a specimen of the ticket, I should think there were a good many more than 10 tickets in there.

Q. Taking that as the specimen, how many tickets would you suppose there was in there?-A. I cannot tell.

Q. I now hand you 10 tickets headed Republican ticket. Please fold these together and compare them with the thickness of that block, and state how much thicker that block is than the 10 tickets you have?-A. 5 or 6 times.

Q. As much as 50 or 60 tickets probably in that block?-A. Yes, sir; I should say so. H. Mis. 23-26

Q. I will ask you to state if you ever saw or ever knew of any paper to be manufactured in this country or elsewhere as the paper upon which that block appears for any purpose.-A. You mean just one thickness, like that!

Q. Yes, sir.-A. I never saw any.

Q. State if, when it gets to the point of card-board and bristol, if it has not ceased to be called paper, and is simply called card-board and bristol; and if it is not known in the business and trade as card-board and bristol board?-A. There are papers, and bristol boards and card-boards.

Q. Ordinary book papers or plate papers or print papers would not be called cardboard or bristol, would they?-A. I am not acquainted with plate papers; I think that newspapers or book papers would not be called bristol.

Q. Or bristol board would not be called book or print paper?-A. No, sir.

Q. It would be known in the trade, and is known in the trade, as Bristol board and card-board?-A. I cannot say. If you were going to buy, and wanted a bristol board, you would have to ask for bristol board. I am not acquainted with the mode of manufacturing bristol board. I have seen something of the manufacture of paper; I have seen it in the process.

Recross-examination by Mr. WILSON:

Q. You call newspaper newspaper?-A. News print is what we call it.

Q. And you call plate paper plate paper, do you?—A. I presume so; but I do not know anything about plate paper.

Q. And you call blotting-paper paper?-A. Yes, sir.

Q. And blotting-paper is made very thick, is it not?-A. Yes, sir.

Q. The stock in card-board is a paper stock, is it not?-A. Well, of course; I do not know how it would be treated. My judgment would be that the stock in bristol board is finer stock than paper.

Q. Do you not think there is a grade of card inferior to certain grades of book-paper stock-A. Yes, sir; certainly.

Q. The stock is though the same stock out of which paper is made?-A. I should just presume that; I would not know positively, because I do not know about that. Of course there are different grades of stock and different kinds of paper. There are exclusively linen papers, and exclusively rag papers and straw papers.

Q. And you may make card-board out of these various materials you have named that are manufactured out of what is called paper pulp ?—A. That of which paper is made; yes, sir.

Q. Now, then, can you make paper collars out of that?-A. Yes, sir.

Q. And they can make cards?-A. Yes, sir.

Q. And they can make car-wheels?-A. I only know that by reputation.

Q. Do they make buckets and such like out of paper?-A. I do not know that.

Q. Do you not know there are 2 large factories-one of them in Wisconsin, one in Iowa--that turn out thousands of buckets made out of paper exclusively?—A. I do not know.

Q. Have you not seen them selling round at the doors of the stores, and are they not used in carrying grain and wheat and anything that is dry to distinguish it from what is wet?-A No, sir.

Q. You did not know there were any such factories?-A. No, sir.

Q. Do not you know that they make rooting out of paper?-A. Yes, sir; paper rooting.

Q. Now, you can make a good many things out of paper?-A. Yes, sir.

Q. Mr. Peelle asked you about 2-ply bristol. Is there a 1-ply bristol?—A. I really cannot say, because I do not know the process of the manufacture of bristol board. Q. Is it not a fact that bristol-boards are made 1-ply, that is 1 sheet as it comes from the mill or 2 thin sheets put together and called 2-ply?-A. I should presume that would be the distinction between the plies.

Q. And you would call it 2-ply card, and 2-ply bristol, and so forth, and is it not true that you may take certain qualities of book-paper and put sheets together and out of that make what is called 2-ply card?—A. I do not know.

Mr. WILSON. I stated to the witness just now, supposing this exhibit which I called his attention to was Exhibit No. 1 to the cross-examination of A. G. Porter, supposing that was made out of Republican tickets. I do not want to be understood to say that it is made out of Republican tickets, for I do not know that it is. The WITNESS. That is what I do not know.

Questions by Mr. PEELLE:

Q. If car-wheels were made out of paper and houses were roofed with paper and buckets were made out of paper, and paper is made into blocks of that kind which has been shown you marked Exhibit No. 1, to the cross-examination of Governor Porter, would the paper then be called book-paper or print-paper ?-A. I should suppose not.

Q. It ceases to be called print or book-paper whenever it gets in any other form than book or news paper?—Ã. Book paper, as I understand it, is distinct. It is not card-board.

E. W. HALFORD.

By agreement of the parties the further taking of these depositions was postponed until Monday, November 26, 1883.

The parties met pursuant to adjournment.

MONDAY, November 26, 1883.

HENRY C. ADAMS, being first duly sworn, testifies as follows:

Direct examination by Mr. PEELLE:

Q. State your name, age, and residence.-A. Henry C. Adams; I am nearly 40 years old, and I live in Indianapolis, Indiana.

Q. What is your business?-A. I am a contractor.

Q. Were you in this city at the time of the Congressional election, November, 1882?— A. Yes, sir.

Q. Did you attend the same?-A. Yes, sir.

Q. I will ask you to state if you were one of the commissioners appointed by the circuit court of Marion County, Indiana, to recount the votes cast for Daniel A. Lemon, James W. Hess, respectively for sheriff?-A. I was.

Q. That election was held when?-A. November, 1882.

Q. Yourself, N. S. Byram, and Austin H. Brown composed the commissioners, did they not?-A. Yes, sir.

Q. Were you sworn to recount the vote for sheriff?-A. Yes, sir.

Q. Was any member of the commission sworn for any other purpose?-A. No, sir. Q. Did you recount the votes on sheriff?-A. Yes, sir.

Q. At the time of that count, I will ask you to state if any one kept a count or attempted to keep a count of the votes cast for Mr. English and Mr. Peelle for Congress? A. Yes, sir.

Q. Who was it?-A. Mr. Austin H. Brown and Mr. N. S. Byram kept part of the vote. Mr. Brown kept all the vote. I think he commenced counting when we commenced counting the vote for sheriff and Mr. Byram kept part of it.

Q. Did you discover any errors in the count of the vote for sheriff?-A. Yes, sir. Q. How were those errors, and in what did those errors consist ?-A. Well, there were a great many errors in this. The board of commissioners made one set of rulings when they counted the tickets in regard to some classes of the tickets, and adhered to them all the way through; and the election officers in the different precincts, about 75 or 80 election precincts, their rulings were not all the same and not all just alike; and there were some tickets rejected that we counted, and some tickets counted that we rejected, and we discovered two or three mistakes in the tallies where the number of votes did not agree with the number of names on the poll-book, and errors of that kind.

Q. Then, in the errors discovered in the vote for sheriff, they consisted, as I understand you, in the fact that the board of commissioners counted several tickets that had been rejected by the election precinct inspectors?-A. Yes, sir; and rejected some that had been counted by them.

Q. Did that comprise all the errors discovered in that count ?-A. No; as I said before, there was some places where the number of votes on the poll-sheet would exceed the number of tickets, and would exceed the names on the poll-book. There was one instance of that kind in one precinct of Wayne Township.

Q. How was that? Just state it.-A. There were 5 more votes counted than tickets; 5 votes tallied for Mr. Lemon more than there were tickets in the box or names on the poll-book.

Q. How was it as to Mr. Peelle and Mr. English in that precinct?-A. I do not remember that there was any difference.

Q. What do you mean by " any difference"?-A. I mean I do not remember that there was any difference between the number of votes as counted on the tally-sheets and the number of votes or the tickets in the box. I will say right here that when this vote was taken the count was kept by Mr. Byram and Mr. Brown, and they seemed to be managing the Congressional part of the business; and Mr. Hess and Mr. Lemon and myself paid especial attention to the count of the vote for sheriff, and the other gentlemen went over all the tickets; I kept no record of that, and I kept no book of it like they did, but I called off the vote. Shall I go ahead and state how we did that?

Q. Yes, sir.-A. Mr. Byram first examined the tickets, and he would pass them to Mr. Brown in tallies of 5, and Mr. Brown would examine the tickets and pass them

to me.

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