Q. What does "job plate" mean?-A. The word "job" designates a job lot-in papers. That may mean almost anything that is irregular.

Q. Why was it billed as a job plate, if you know?—A. Because it was not plate paper in every particular.

Q. Did the size of the paper have anything to do with the sense in which it was billed?—A. I think so; it was a plate size.

Q. Is there anything else about this paper to designate it as a plate paper, except the size; if so, state what it is?-A. There is nothing to designate it as plate paper, except paper of the same quality and grade is called Western plate-technically known as Western plate, which is not plate at all.

Q. How are papers billed in the trade and sold in the trade?—A. That is, I suppose, a hard question to answer.

Q. I mean how are they billed?-A. They are billed according to their size, weight, kind, and grade.

Q. Does the bill show that it is paper, or is it billed in some other way?-A. Everything about the bill would show it was paper.

Q. Does the word "paper" appear on the bill in the purchase of paper?-A. No; paper is understood. It would just be using the word "paper" over and over again. Coming from a paper house they understand that paper is meant.

Q. How would news or print paper be sold or billed?—A. Billed merely as news. Q. The word "paper" would not follow?-A. The word "paper" would not follow; the size, weight, and number of reams would appear, and sometimes as to whether it was flat or folded,

Q. Suppose it was billed as S. & S. C. tint, what would that mean ?—A. It would mean sized and supercalendered tint paper.

Q. The word "paper" would be understood?-A. Yes, sir.

Q. Have you the bill of this paper?-A. I have.

(Objected to as incompetent, for the reason that the bill speaks for itself.)

Q. How many different kinds of paper are contained in that bill?-A. I cannot answer without examining the bill. I could answer in this way; that there were a number of items on the bill, but I could not state what they were unless I would see the bill.

Q. The bill of this paper with the other paper is pasted in your bill-book?-A. Yes, sir; my invoice book.

Cross-examination by Mr. BYNUM:

Q. What are your politics?-A. Republican.

Q. Were you a member of the Republican county executive committee of Marion County that had charge of the Republican campaign for Congress in this district in 1882-A. I was.

Q. You say you printed the ticket used by the Republicans at the election in November, 1882, specimens of which were shown you by Mr. Peelle, headed "Republican ticket." Who gave you the order to print those tickets?-A. The order was given to my superintendent, Colonel Ruckle.

Q. What position did Colonel Ruckle occupy on the Republican executive committee?-A. None.

Q. What are his politics?-A. Republican.

Q. Do you know who gave the order for the tickets?-A. I think Ransdell gave the order. I am pretty positive of it; Daniel M. Ransdell.

Q. He was the chairman of the Republican central committee of Marion County at that time?-A. He was.

Q. Was the order verbal or written?-A. Verbal.

Q. Can you state how many tickets were ordered to be printed?—A. I am not positive, but I think 100,000.

Q. Was there any entry or memorandum made by you or Mr. Ruckle or any person in the office, of the kind, quality, and character of the tickets that were to be printed at the time the order was made?-A. No, sir; there was a charge made on the book, but that would not cover what you asked.

Q. What was the charge made upon the books for-for the value of the tickets?— A. Yes.

Q. When the order was given was there any character or quality of paper designated upon which it should be printed by the party ordering it ?-A. It was understood that the ticket was to be printed upon this paper.

Q. Upon what paper do you refer to ?-A. The paper upon which the tickets were printed.

Q. In your examination-in-chief you stated you ordered the paper upon which the Republican tickets shown you were printed, as well as the others used generally in the election in 1882 in this district-the last of October in 18827-A. Yes, sir.

Q. State if you ordered that paper especially to be used in printing these tickets.A. I did.

Q. How did you come to select that character and quality of paper -A. Because paper of good quality, good weight, and good color was wanted.

Q. Why was paper of good quality, good weight, and good color wanted!—A. That is a hard question for me to answer; because it was natural to want that kind of paper. I do not want to give any answer that would seem like an evasion in any

way.

Q. Is the material upon which the Republican tickets are printed print or new paper?-A. Print and news paper are the same thing. This is book paper.

8

Q. That does not answer the question. The question is, was the material upon which it is printed print or news paper?-A. Neither; I would say neither. Both print and news paper are the same thing-news and print paper.

Q. Is it ordinary book paper, such as is commonly used in printing?-A. It is. Q. What class -A. I would like to ask you before you ask that question what you mean by ordinary and common.

Q. Such as is commonly and ordinarily used as to quality, and common as to the general printing of books.-A. Yes; in that sense it is common and ordinary.

Q. What proportion of printing done in your office is done upon that quality and character of paper?-A. The work done in my office is so various that it would be impossible to tell.'"

Q. Give some opinion or some estimation.-A. Did you ask me to answer in relation to the price or bulk?

Q. The proportion of the work-more than likely to space than anything else. What fractional portion of your printing do you do upon that paper?-A. Well, I would say 99 in a 100 of all bound printed books are printed on this, or a trifle better, grade of

paper.

Q. Do you mean to say 99 out of 100 books are printed upon paper as heavy as this upon which the Republican ticket is printed?-A. I do not.

Q. You answered that 99 out of 100 books printed in your office.-A. Yes, sir; printed bound books, I said.

Q. What do you mean by printed bound books?—A. I use the word "bound" in contradistinction to pamphlets-in contradistinction to pamphlet work.

Q. What are the books printed in your office, which you have designated as bound books, used for ordinarily ?-A. Printed to read.

Q. What books are they? Give a description of the works.-A. I could not do that. Q. You can name some of them; come as near as you can.-A. Name some of the jobs we have had?

Q. Some of the works, the legal works, or literary works, or statutes.-A. The revision of the ordinances of the city of Indianapolis and the reports of the proceedings of the grand commander of the State of Indiana Knights Teniplar. I cannot readily call them to mind, but any number of those jobs.

Q. Any other books printed by you during the last year?-A. Yes, sir.

Q. Name them; other bound books.-A. It is impossible for me to call up now the jobs I have had. Understand me, I want to give all the information I can.

Q. Do you mean to say that the ordinances of the city of Indianapolis are printed upon what is called Western plate paper?-A. They are printed upon the same grade of stock; paper of the same grade.

Q. That does not answer the question. I want you to answer the question directly whether they are printed upon what is called Western plate paper?-A. They are not. Q. What proportion of the work done in your office in printing bound books is done upon what is called Western plate paper?-A. Very little, or none of it.

Q. What portion of the works printed in your office-bound books-are printed upon material similar to that upon which the Republican ticket shown you was printed; similar in weight and quality?—A. Upon material similar. Now, you do not refer to weight, do you?

Q. Yes; I refer to weight when I refer to material, similar in kind.-A. You say material. Material may be large and small; it may be thick and thin, all the same matter. Ivory is ivory whether it is in an elephant's tusk or a toothpick.

Q. But the quality is the same?—A. I think you are wrong; I want to answer you

and would like to do it.

Q. That is what I want.-A. A tree is a tree, but one may be thick and another thin; but it is a tree all the same.

Q. (Question repeated)-A. Very little.

Q. Have you printed a solitary book within the last 12 months upon paper similar in weight and quality to that upon which the Republican ticket is printed?—A. None that I know of.

Q. Have you ever printed a book to your knowledge upon similar material in quality and weight?-A. No.

Q. Did you ever print a newspaper upon similar material in quality, weight, and finish-A. No, sir.

Q. Did you ever before print election tickets upon material similar in quality, weight, and finish?

(Objected to as immaterial.)

A. The ticket used in the last Presidential election in 1880 was-I want to say it was similar in weight-but I want to qualify a little bit. If I had one of them so I could feel it I could tell you at once. My recollection is in weight it was very similar and very near as heavy. I will say the Republican ticket of 1880.

Q. You have stated that you are engaged in purchasing printing paper. Do you say that the material-the quality, finish, and weight-upon which the Republican ticket is printed is such as is ordinarily used in printing books or newspapers?—A. I do not.

Q. For what purpose is the character of paper in quality, weight, and finish upon which the Republican ticket was printed ordinarily used in your business?-A. Various kinds of job work.

Q. What class of job work?-A. I do not know how to designate it by class. Q. I suppose you might say cards and programmes?-A. I could name some items of programmes; I remember now of some progammes printed on paper like that.

Q. What is the weight of the paper upon which the tickets shown you by Mr. Peelle, designated as the Republican ticket, is printed as compared with common book or print paper?-A. Did you say common size of book or print paper?

Q. Per pound I mean.-A. The weight is always governed by the size of the paper. Q. Similar size sheets, 25x38?—A. I think that weight is relative to a 25 x 38 sheet, 80 pounds in weight.

Q. The Republican ticket?-A. Yes, sir.

Q. What is the weight per ream of the paper upon which the Democratic ticket as shown you by Mr. Peelle was printed, sheets of the same size?—A. 25 x 38?

Q. Yes, sir.-A. 25 x 38 sheets, I think, would weigh 45 pounds.

Q. I believe you stated that 100,000 tickets were ordered?-A. That was my recollection; may I refresh my recollection by asking Mr. Ransdell if I am right. Mr. PEELLE. Never mind; just answer his questions, and nothing else.

Q. What was the cost of the paper upon which 100,000 tickets was printed of the kind, quality, and size stated by you as ordered?—A. Used on the Republican ticket? Q. Yes, sir; as Exhibit No. 1 to Mr. Sexton's depsition?-A. Give me a piece of paper, and I can figure the cost. [After figuring] $55.46.

Q. What would be the cost of the same number of tickets printed upon sheets of like size and of the weight and quality of that upon which the Democratic ticket was printed, marked Exhibit B to Mr. Holliday's deposition ?-A. [After figuring] $29.45. Q. I will ask you the same question as to the National or Greenback ticket, used at the election in 1882?-A. It would be about a cent and a half a pound less; it is about 37-pound paper. Do you want me to calculate on that paper?

Q. Yes, sir; perhaps you had better look at the Democratic ticket, and see if you have that weight right.-A. It is 45-pound paper.

Q. What is the National ticket?-A. That ticket I can tell more about. It is a chemical wood paper, and it appears heavier than it weighs by about 6 per cent. Mr. PEELLE. What National ticket do you mean there?

Mr. BYNUM. The National or Greenback ticket voted in November, 1832, and marked Exhibit No. 2 to the deposition of W. O. Anderson.

The WITNESS. $21.40.

Q. Why did you print said Republican tickets on heavier material, which cost, as you say, $55.46, when, as you say, you could have had the same tickets printed on plain white paper, such as the Democratic ticket was printed on, for $29.45, or plain white print for $21.45, such as the Greenback ticket?

(Objected to as immaterial.)

A. You ask me as the printer?

Q. I ask you to answer that question why you selected this paper that cost so much more when you could have had just as good tickets printed upon ordinary white paper?-A. In the first place you could not have had as good a ticket printed upon a thinner and cheaper paper; that is what makes it difficult for me to answer. I do not think that they would have been as good. I think the tickets ought to be heavier. Q. Is that your answer to the question?-A. Yes, sir.

Q. Wherein is the material on which the Republican ticket is printed any better than the material on which the Democratic ticket is printed ?—A. Because it is better stock and worth more money and cost more.

Q. It cost more?-A. Because it is worth more and cost more and is better.

Q. Do you mean it is better for tickets?-A. Yes, sir.

Q. You stated that Mr. Rausdell selected this paper upon which these tickets were ordered upon your original examination; when was that selection made?-A. I stated that Mr. Ransdell gave the order for the tickets.

Q. Who selected the material upon which they were to be printed ?—A. I selected

the paper when I bought, and Mr. Ransdell selected this paper when he ordered the tickets printed.

Q. You selected the paper when you bought it ?—A. Yes, sir; that was my business. Q. Did you see it before Mr. Ransdell selected it for a ticket or afterwards?—A. I bought it about the same time.

Q. Did not you state in your testimony a short time ago that you ordered this paper on purpose-A. I did, and that is what I answered now; that it was done at the same time.

Q. Then the order for the tickets was made before you ordered the paper?-A. No, sir; it was not. When I bought that paper the committee did not know how many tickets they wanted and they did not give the order.

Q. They had agreed that it should be printed on the kind, quality, and character of that paper?-A. Yes, sir.

Q. Where was that agreement made?

(Objected to as incompetent, for the reason that it assumes that there was an agreement.)

A. I could not answer.

Q. Can you state who was present at the time the paper was agreed upon, and by and between whom it was agreed upon?-A. By Mr. Ransdell, Colonel Ruckle, and myself.

Q. Who recommended this kind of material?

(Objected to as immaterial.)

A. I do not know that anybody recommended it.

Q. Did you have a sample of the paper present at the time it was agreed upon ?—A. Each of the parties that I mentioned were familiar with the paper and had examined it, but whether at the exact moment the agreement was concluded that it was to be printed on this paper the sample was by them and in their hands I do not know and could not tell.

Q. When and where had each of the parties examined this quality and character of paper?-A. Mr. Ransdell was first shown a sample of this paper in my office the ay Mr. Wing exhibited his samples of paper to me, and the day on which I made the purchase.

Q. When did Mr. Ruckle examine it ?—A. Mr. Ruckle saw the paper the same day and examined it.

Q. Did you then agree among yourselves that the ticket should be printed upon that character and quality of paper?-A. I do not know that we agreed among ourselves on that day that it should be done.

Q. Did you have any understanding on that day?-A. Not definitely; at least I do not know that we had definitely on that day; I do not think we came to the conclusion to select the paper and our minds were made up that day.

Q. Where was that examination made; in your office or building?-A. As I stated, the paper was first shown to Mr. Ransdell in my office, and Col. Ruckle first saw it in my office.

Q. Was Mr. Wing present at the time it was shown to Mr. Ransdell and Mr. Ruckle-A. He was present at the time it was shown to Mr. Ransdell.

Q. Had you any of this kind of paper in stock at that time?-A. I had.

Q. How much ?-A. Not a sufficient quantity to print the tickets.

Q. Did they examine the paper in stock, or that sample shown by Mr. Wing?— A. The sample shown by Mr. Wing.

Q. Who first suggested that this paper should be used for the purpose of printing election tickets?—A. I did.

Q. What was your object in suggesting this character and qualityof paper?—A. To meet the views of the commitee in having a paper of excellent quality, and good color, and good weight.

Q. Is that all the object you had ?—A. That was all.

Q. What do you mean by good weight; do you mean extra weight, or donble weight, or common book paper, or print paper?-A. Above an average weight.

Q. Do you mean above the ordinary weight of common print or book paper, such as commonly used?--A. I think my answer, an average weight, is as clear and distinet as I can answer that question.

Q. What is about an average weight?-A. I cannot tell definitely; what kind of paper do you mean?

Q. Common book or print paper?-A. You see they are two different things.
Q. Common book paper first?-A. 60 pounds.

Q. Is that an average of common book paper?-A. It is a common average of he better qualities of book paper.

Q. Of common ordinary book paper?-A. If that is what you mean, I want to change that 60 pounds. If you are talking about common paper, we use lighter weights than that. Let me change that answer. If you want common book paper, I will say the common weight of common book paper is 50 pounds.

Q. What is the average weight of common print or news paper?-A. 50 pounds. News paper runs in more different sizes than book papers.

Q. In your testimony I want to designate it in sheets, size 25 × 38.—A. Then I will say on the print I will change that to 25 x 38 print, 40 pounds as a print paper. You see, news paper is usually larger size.

Q. What advantage was there in printing the Republican ticket upon paper as heavy as that upon which they were printed?-A. There was no advantage, provided they were not printed on paper a great deal thinner.

Q. What advantage was there in printing them upon paper of the kind, quality, and weight upon which they were printed, as a ticket, over the kind, character, and weight of paper upon which the Democratic ticket was printed, marked Exhibit B to the deposition of C. F. Holliday?

(Objected to as immaterial, for the reason that it assumes that the paper upon which the Democratic ticket was printed is the standard under the law.)

A. In my judgment, the paper upon which the Democratic and National tickets shown to me as exhibits were printed is too light and too flimsy for such use.

Q. Is not the Democratic ticket marked Exhibit B to the deposition of Mr. Holliday printed upon a paper considered an average in weight and quality of paper in common use for printing purposes?—A. It is a common weight and quality of No. 2 western book.

Q. State why, in your judgment, you think the Democratic ticket is printed upon paper that is too light and too flimsy to be used.-A. The statement that you refer to carries its own answer; because it is too light and too flimsy. Those are the only reasons I have.

Q. You can assign no other reason than you stated in your last answer?—A. I

cannot.

Q. State whether or not you did not select this paper upon which the Republican tickets were printed, as shown you by Mr. Peelle, because it was a heavier, more polished paper, and could be told from that of ordinary book or common print paper? (Objected to as immaterial and assuming that the witness selected the paper upon which these tickets were printed.)

A. I did not. If you would put that as to the recommendation, I would say it was a suggestion instead of a selection, and then you would get an answer to your question. Q. State whether or not you did not recommend to Mr. Ransdell the paper upon which the Republican tickets were printed, as shown you by Mr. Peelle, because it could be told from a ticket which was printed upon common book or print paper by sight?

(Objected to as immaterial and assuming that the witness had knowledge of what kind of paper the Democratic and National tickets were printed on.)

A. I did not. Can I give you a reason for my answer?

Q. That answers it.

Mr. PEELLE. You have a right to explain any answer you give.

The WITNESS. I did not, for the reason that I had no means of knowing upon what kind of paper the Democratic ticket would be printed.

Q. Did not you recommend that kind of paper to Mr. Ransdell because you thought that the Democratic ticket was less likely to be printed upon that than any other kind or quality of paper?-A. I did not.

Q. Have not the Democrats in Marion County printed their tickets generally upon the same kind and quality of paper as that upon which the ticket marked Exhibit B to the deposition of C. F. Holliday is printed?-A. I do not remember.

Q. Did you buy any such material as the Republican ticket is printed upon from Mr. Burford, in the city of Indianapolis, the day before the election? (Objected to as not cross-examination.)

A. I did not.

Q. Did you buy any such paper from Mr. Burford at any time near the election ? (Objected to as not cross-examination.)

A. No, sir.

Q. Did you purchase any lithographic plate paper from Mr. Burford about that time?

Q. Did you get any from him about that time?

(Objected to as immaterial.)

A. I got some paper, known as western plate paper, from Mr. Burford about that time. I borrowed it.

Q. When did you borrow that?-A. A few days before the election; I cannot tell you the day.

Q. How much did you borrow?-A. I do not remember.

Q. Was not the paper billed to you ?—A. It was not.

H. Mis. 23--28