The New York herald., 1869-12-01

9th respect OF the estimation in which they hold
It's MANAGERS and the interest they feel IN is pro-
sperlty and good name Seventh, that this de-
moralizaton has been Increased by the general con-
demnatlon OF such managers IN the public Journals,
ana BY carlcatures OF some OF them, freely circu-
lated from the company and stations. Eighth,
that the recent strikes ana combination among the
employees are OF character not before known the
ne are 10 DC traced 70 the facts and causes herein
before referred TO- ana are OF threatening charac-
ter, and are likely TO be highly preJudicial
some appropriate remedy shall be speedily applied.
Ninth that among the reasons Of the present state
OF feeling ana want OF discipline on the road is q
CONVICTION among the men that the present man
ayers nave not the requisite qualifications as man
ayers OF such corporation that their attention IS
too much gwen 20 outside matters; that they inter-
Iere with the relations between The higher grade OF
agents ana those below and with the due anu usuai
order OF promotion; that they introduce political
elements into their management, and that they 90
not command general public respect: and during
deponents service under President Gould he was
his tdeponent,s Influence 70 promose the election
OF q person named by the president Gould;
and during the recent State election deponent IL IN
formed and believes, that the managers OF the line
made especial efforts to secure by tile votes OF the
employees OF the line the election OF a state officer,
from the exercise Of whose official power ne ID told
they had something 10 fear II not concated.
Will further state, IN answer to your inquiry, that
during the last year, and especially or late, there
experienced men dismissed from the ne,
and inexperienced appointed In Their places.
poyed on the road only remain because they cannot
afford TO leave at the peril or having their ability 10
get employment elsewhere impaired by damaging
and unfounded reports; that they would much pre-
fer service other roads at the same rates; tnat
they understand they will be dismissed II they
openly condemn the management and from much
opportunity or getting at the facts cannot hesitate
to say that the employees and agents genA. ally con-
denim the present managers in severe terms when
they think It safe TO freely express their views and
feenngs. q. w. DOUGLAS.
sworn TO before me. this 18th day OF November,
1s69.-JoHN HAYES, Notary Pubic in and for New
York county.
AFFIDAvIr OF JOSEPH H. RAMSEY.
Joseph H. Ramsey, being sworn says that he Is the
plaintiff in this action and mat he has examined
into the facts and transactions mentioned IN the
complaint herein, and has consulted such docu-
menLs and obtained such information from other
sources entitled 10 credence, and being the best
available, that ne Is fully convinced OF the substan
tal truth Of the allegations therein contained, and
on information and belief he AYERS the same TO be
true And he refers TO the several parts OF the COM
plant hereinafter enumerated and makes them a
part OF this aflidavit II herein repeated. Refer
ring to paragraph numbered three, begin
ming at folio twenty-tnree Of the complaint,
he says he has caused the facts there stated
to be carefully ascerlained ana mas s. examined the
are taken. And, referring TO fourth and nth
paragraphs OF the complaint, he says he has con-
suited reliable sources OF information and Is fully
satisfied Of truth OF the allegations therein
tanned. Ana, referring to the paragraph OF the COM
plant numbered 8, he SAYS ne mas examined the
artcles,n bylaws and rules therein referred to and
thinks he understands them, and that TO the best Of
his understanding thereof the allegations oil said
paragraph ore correct And, referring to para
graphs respectively numbered T. g. o, 10, H. r. IL,
a. l5 IT, IL 49, 10, 20, u Of the complaint he says
he obtained much reliable information OF the trans
actions therein referred to as the same were
Transporting; that ne has looked into the pub
llshed proceedings OF the court concerning the
same, and got at % many OF the , facts az to
same; that he was in Albany during parts Of the
periods therein referred to; that he has seen the
papers In several OF the suits referred to, copies or
affdavlts OF persons knowing and stating many OF
the leading facts and from lnose sources has good
reasons for stating the truth OF the matters IN such
paragraphs Il 10 81 nclusve) last referred to- And
referring to paragraphs of the complaint numbered
% 23 "a 25 30 ~, 20, 30, CO. 81 81 33, "a, 3d. 36
81 and SO, he says he has consulted The best sources
of Information known TO be open to hlm and has de-
rived his Knowledge from reiiaDe sources, including
papers therein referred 10, and from said
Information AYERS the truth ana his belief OF the
allegations OF those portions OF the complaint
And referring 10 the paragraphs numbered
49, 49, A. AZ and As, he says ne seen portions or
the other papers, and the complaints therein referred
to- ana he AYERS the allegato of these paragraphs
are well rounded, according to the best information
he can obtain. And referring to paragraph num-
bered A, he alleges, on information and belief,
that the allegations therein contained are true.
Ana referring 70 Paragrapas Sa p numbered % 70 40 ~
writing Of Jay Gould, requesting subordinate on
the Erie Railway, III charge OF numerous employees,
to use his influence To secure the election OF partl-
cuar candidate, and on information and belief de-
ponen alleges the allegations in sad several para
graphs to be true. And referring TO the para
graph numbered 40, he says he has learned
the leading facts therein. stated from sources
entitled TO credence. and has seen printed
referred TO- And referring TO paragraph numbered
3d. he alleges, on information and belief, that the
allegations ia the same are true. And referring to
the paragraph numbered 81, he says he has seen o
printed copy OF the complaint therein, from which
The leading facts stated are taken. And referring to
the paragraphs numbered 50, 5S 81 So 56 81. 5S, So
co. 81 49, 64 65, &c. 81, 6s, 90, 20, Il, ~ 49, IA TO-
76 II and IS, he AYERS, on information and belief
that the allegations therein contained are true and
90 ia rpsOlutlOnQ therein o.
crred have been treated as correct by those best
informed OF the facts to which they refer. And
deponent desiring to get in'orInatlon If possible
from some OF the Directors OF the Erie Railway
Company, has caused inquiries to be made, but
could thus secure no important information ex-
cept nom MIR. Diven, one OF the directors, to
whom one OF the dep0nent's attorneys addressed .
letter and received an answer to the same, OF which
copies are herewith attached, marked respectively
schedules A ana B. and on information and belief
deponent AYERS the statements contained in said
answers are true. JOSEPH H. RAMSEY.
sworn to before me, this l7rh day OF November,
1s69.-L. G. BANCROFT, Commissioner OF Deeds, city
OF Albany, n. \.
Mr.. Field said 1t probably would be necessary IN
disposing OF this otion that reference should be
ordered TO ascertain certain facts. For example,
Mr.. Eaton said that no aiildavt was served on nfm
The affidavit Of service which he had in the case
stated positively that the adavlts Of Mr.. White and
Mr.. Whitaker were served on him with the COM
plaint. or course there was some mistake and ne
did not think they could get at 1t without ref
erence.
Mr. Eaton said he made the afllaavit according to
facts. Whether the papers were served or not was
utterly immaterial. II 1t would facilitate the
sci In coming OF the substance Of the case and dis
posing OF 1t That day. ne would admit that The papers
were served for the purposes of this argument.
MIR. FIELDS ARGUMENT.
Mr. Field said that before he read portions OF these
papers he would say that he dwet longer on TINS
notion than he should otherwise have done because
OF the very great misrepresentation In respect 10
this order and the action Of the Court which mad
been made In the newspapers. or course he could
suppose that any such Misrepresentation were
tended but they wcre nevertheless, very prejudical
to Justice the and ought be set right Now,
fair play was characteristic Of this people and Of
the brave people from which they were descended,
aud the first lesson in their code OF honor that
no man should be cOndemed unheard. And
when he told his Honor that in this case
eight directors out ol seventeen OF the
Erie Railway Company had been struck
with an order OF suspension which would paralyze
them without giving them an opportunity to say
that II ought not to be done, was there ANYTHING
grosser In fhe whole history OF iurisprudence than