The New York herald. [volume] (New York [N.Y.]) 1840-1920, 1876-01-09
THE BROOKLYN RING SUITS.

ANSWER OF THE CONTRACTORS IN THE HEMP
STEAD RESERVOIR LITIGATIoNs.
Yesterday the counsel for Messrs Kingsley and Kee-
ney served the answer in the complaint made against
their clients the contractors for the Hampstead Reser-
voir, Mr.. John E. Parsons who is prosecuting the
suit on behalf OF the Attorney General of the State
The following the text of the answer
Supreme Court City and County of New York
The People of the State of New York William c.
Kingsley, Abner G. Keeney William A. Fowler Edward
J. Lowber and Archibald NJ Bliss, defendants.
The defendants, William G. Kingsley and Abner O.
Keeney, by Tracy Cat.n their attorneys the
plaintiffs complaint herein in manner and form fol-
lowing, that is 10 say
First-They admit the facts stated and alleged in tho
first, second and third paragraphs OF said complaint
Second-They admit tho facts stated and alleged in
the fourth paragraph of said complaint except that the
specified rates and sums which the Permanent Board
OF Water and Sewerage Commissioners agreed 10 pay
TO the said defendants for such work, which, upon
those OF the quantities estimated for the SAID reservoir
in the specifications prepared by and under the drec
tons OF the SAID Board, included in the schedule Of
balanced bids. amounted to the sum OF over ST. 37 400
which allegation the said defendants deny.
TatrdIhey deny that under said contract there has
been paid TO said defendants by the city of Brooklyn,
for work done under and in pursuance Of the terms of
said contract the sum- In all, OF ll5l, 1874 is, or
whereabouts, as alleged in the fifth paragraph OF said
complaint; but they aver that the whole that has
been paid TO them under said contract is 004 1877 o.
They deny each and every other allegation in said par
agraph OF said complaint contained
EourhThey admit the facts alleged and set forth in
the sixth paragraph of said complaint TO be therein
ana set fOrth, SAID defendants
that at all times IN sad complaint mentioned the de-
PENDANTS, William A. Fowler, Edward j. Lowber and
Archibald w. Bliss, constituted the said Board Of Per-
manent Water and Sewerage Commissioners.
FJnl-Averring that the allegations contained in the
seventh paragraph OF said com aint are wholly mma-
teria aud irrelevant the said defendants neverthe-
less, deny the same
Sirth-They deny each and every allegation con-
tanned in the eighth, ninth, tenth eleventh, twelfth,
thirteenth fifteenth, sixteenth and eighteenth para
graphs OF said complaint except that they admit upon
Information ana behef the averment in the eleventh
paragraph of said complaint, "that after the
passage of sad act Of February, 1871, the
the said Permanent Board OF Water anc Sewerage
Commissioners, caused specifications for the work
upon the said reservoir to be prepared" And they nd
nit, upon information and belief that said Commits
did advertise in any public newspaper for
bids but they aver that said Commissioners did invite
proposals from many competent contractors engaged
in constructing public Of the description OF said
reservoir and did in good faith endeavor TO secure,
and did secure, honest and sufficient competition in
bidding for SAID work and they also admit that the site
Of the sad reservoir consisted In part OF previously
existing ponds deposits Of water That by drawing
of such the expenses OF excavating the ground
by II could be greatly reduced stated in the
thirteenth paragraph OF said complaint
That of the matters alleged and forth In the four
teenth and seventeenth paragraphs of said complaint
the defendants they have knowledge but upon
information and belief they deny the
Wherefore these defendants demand judgment for
the dismissal Of the complaint herein, with costs.
TRACY X CATLIN,
Attorneys for defendants Kingsley and Keeney
County of Kings s.-William c. Kingsley and Abner
c. Keeney. the above named defendants being
orally and duly sworn each for himself says that the
foregoing answer is true Of his knowledge except
10 matters therein stated on information and belief
and as TO those matters believe II 10 be true.
WILLIAM C. KINGSLEY.
ABNER c. KEENEY.
Sworn TO before me this Sth day OF January. 1876
john =. HUDSON Notary Public, Kings county.
Argument for change Of venue from New York TO
Kings county will be made in the Supreme Court OF this
city behalf Of the defendants on the third Monday
January.