The New York herald. [volume] (New York [N.Y.]) 1840-1920, 1878-12-07

eating Infants and others lttuh1afy ftNIOH-
sbily or legal liability whatever, and that said sub
scrptons not legal nor binding and could not be
collected. and that the said Rev. T. DE Witt Talmage
and Others officers of the defendant, who were know
ingly decoiyng the congregation, well aware OF
that fact when they allowed said pretended subscp-
tions to be publicly announced; that many persons
being deceived by the announcement so made afore-
SAID of these illegal and bogus subscriptions We're IN
duced to, and did subscribe various amounts for the
purpose aforesaid.
Eightt-And the plaintiff further alleges that the
statements SO made 70 saa as afores No.
sum OF $70.000--and that $4,000 thereof had been
subscribed, leaving balance of only $4,000 to be
provided for-were untrue, and so known to be at
that time, by the said Rev. L. Dewitt Talmage and
Others officers of said defendants. and that said state
ments were made for the purpose and with the in
tent of deceiying said congregation. and many
deceived by said false statements. and induced
thereby to subscribe and did subscribe toward the
Ninth-Plaintiff further alleges, on information
and belief that at the time it was announced that
the bona dde subscriptions toward said debt did not
the Of $4,000, and the total Indebtedness
Of the defendants at that time exceeded ss5,oOo.
THAT JUBILEE" MEETING.
Tenth-And the plaintiff farther alleges upon in
formation and belief that for the purpose of further
been member, the Rev. T. De Witt 1almage and
Others officers OF said defendants, caused Jubilee
meeting to be held in the Tabernacle, on or about
the 29th day of May, 1873 for the purpose of rejoc
ing over the payment of debt that had not been paid
and exulting free church overburdened with debit
L.
Witt Talmage, A. w. Tenny, John Winslow, DR.. JEFF
frey, Rev. DR.. Lyman and other distinguished clergy
men and citizens were present, and at said Jubilee
purpose and with the intent aforesaid untruy stated
that the entire debt of defendants had been
paid and that the vos ''sunk in the
midst Of the sea- That number Of distinguished
persons present, being misled as to the facts. un-
knowingly gave the weight Of their influence in aid
of the deception that being practised upon said
congregation and the plaintiff The said A. w. Tenny
said-"As citizen OF Brooklyn, am rejoiced to be
is achievement worthy of all praise 1t is something
of which the Church may well be proud. am glad
that you have paid your debt Dr. jeffrey said; 81
congratulate YOU that you have paid of your debt
Rev. DR.. Lyman said :-;You have buried your
debt from your church wallis; it was a
splendid Offering" John Winslow said: -"H Brook
Ign be proud Of tabernacle in debt how can she
glorify high heaven for a tabernacle out OF debt.
That at the very time this mock Jubilee. meeting
valid and subsisting mortgages upon the very build
ing in which this scene was being enacted-one for
Liber 1.l72 OF mortgages, page aoI' ana one ior
$21 000 recorded in said Office in Liber l2eO of mort
cages, page 503 besides other Indebtedness, amount
ing altogether to upward of Ss5,OOO.
UNPAID DEBTS.
Eieue,,0t-That the defendants thereafter and or
about the day OF September last sold and disposed
cefain property belonging to it, consisting Of the
old church property, and used the proceeds thereof
toward paying on portion or the indebtedness or
and belief, that there now due and unpaid debts
owing by the defendant to various persons and cor
porations exceeding the sum of $63,OOO.
T,ceyM-Plaintif further replying to so much of
the answer Of the Defendants alleging pretending to
alege counter claim herein, denies each and every
allegation therein contained.
Wherefore plaintiff demands judgment against de-
PENDANTS as demanded in the complaint.
MORRIS IL PEARSALI.. Attorneys for Plaintif.
City Of Brooktyvs, County Of Kings, William J.
Geston being duly sworn says he is the plaintiff in
this action. that the foregoing reply is true Of his
own knowledge, except to the matters therein
stated to be information and belief and to those
matters he believes it to be true.
WILLIAM J. GEISTON.
Sworn to before me this 9Th day of December 1878,
GEORGE w. RoDEEIcK, Notary Public, Kings county.