The daily gazette., 1880-12-08
Judge HOustOn's Contest.
THE NOTICE SERVED UPON HON. 4. L.
MARTIN.

DOVER, Del, Dec. 3, 1880.

contest your seat as Representative of
the Congressional District of the State
Of Delaware in the Forty Seventh
Congress of the United States of Amer.
lea, and the following are the particu,
lar grounds upon which l shall rely in
said contest, viz:
LIST. That at least one thousand free
male citizens of the United States of
America, of the age of twenty-five
years, or upwards, having resided in
the State OF Delaware, one year next
before the election for Representative
for the aforesaid District in said For
ty-Seventh Congress, held in said State
on the second day of November last,
Ga. D. 1SSO,) and who we're in every
respect duly qualified TO vote at said
election under the Constitution and
Laws of the United States, were hin
dered, debarred and prevented from
voting at said election by reason Of the
wrongful acts and omissions of the per-
sons and officers charged by the Laws
of said State with the duty of assess
ing persons and property, residing and
being in the several counties of said
State, each and every of which said
free male citizens had they not been so
hindered, debarred and prevented
would have cast his vote for me for
Representative as aforesaid at said
election.
I'd. That at said election in count>
ing the ballots, sundry ballots, amount
ing in the aggregate to more than five
hundred were counted for you by the
judges of said election which should
have been counted for me for such Rep
resentative as aforsaid.
Sd. That divers persons, number
ing at least one thousand, who were not
duly qualified as electors, in respect of
the preI quisite qualification ofhaving
within .wo years, next before said cleo
ton, paid county tax assessed at
least six months before said election,
unlawfully voted for you for Repre-
sentative as aforesaid, and their bal
lots were counted for you at said cleo
ton.
4th. That more than one thousand
persons who were duly qualified elec-
tors, and entitled to vote at said elec-
ton, and who offered to vote for me
theTeat for Representative as aforesaid
were unlawfully prevented from so do
ing by the refusal of the judges Of said
election to receive their votes and count
the same for me.
9th. That large number of ballots
amounting in the aggregate to at least
six hundred, which were given for me
and received by the judges Of the cleo
tion at the proper voting places for
Representative as aforesaid we're not
| counted for me by said judges.
9th. That at the several hundreds
and voting places in the said State OF
Delaware al least Six Hundred more
votes were counted for you than were
given for you for Representative as
| aforesaid.
7. That at the several Hundreds and
voting places in the said State a less
number of votes was counted for me for
Representative as aforesaid by the
| Judges of said election by at least Six
| Hundred than there were ballots given
| for me for such Representative.
s. That in many of the Hundreds and
voting places of the said Congressional
| District unnaturalized foreigners to the
numbers OF at least Six Hundred unlaw-
fully voted for you for such Representa-
| tive anil their ballots were received and
counted for you.
9. That in each Hundred and voting
place III said State divers persons un-
lawfully voted, and their balloJs were
received and counted for You for such
| Representative who had been placed on
the Assessment lists of the said Hun
dreds respectively contrary to the pro
| visions of the Constitution and Laws OF
said State Ia that behalf amounting in
the aggregate to at least six hundred
| votes.
| 10. That in each and every Hundred
aud voting district in said State persons
| were unlawrully allowed TO vote whose
ballots were received and counted for
YOU for such Representative as aforesaid
upon Tax Receipts which were placed
| in their hands pretending to show that
thew had County Tax within TWO
wears, which had been assessed at least
ak months before said election;whereas
said persons so unlawfully voting in
truth and in fact had not paid such
County Tax, agreeably to the provisions
of the Assessment and Collection Laws,
then and now of force and in virtue in
said State.
IL. That certain persons contriving
and intending unlawfully 10 defeat the
operatiop of the fifteenth Amendment
of the Constitution of the United States
af America, and the Law OF Congress
passed In pursuance thereof to enforce
the same, combined, consplred anu
agreed among themselves to hinder,
obstruct, prevent and exclude legal ana
qualified voters from exercising the
right of suffrage, and in pursuance oil
that combination, conspiracy and agree,
ment did draft and procure to be passed
nv the General Assembly OF the state OF
Delaware an act entitled, Gan act In re-
Iation to the duties Of Assessors aud OF
the Levy Courts in the several Coun-
| ties of this State," passed at Dover,
April 8, 1873, the same being chapter
3T1. vol. IA, Laws Of Delaware page
$40 r, c., aud also a certain other act OF
, the General Assembly of said State, en-
7 titled. San act in relation to the coiiec,
; lion of taxes in this State, passed az
: Dover. April 10, 1878, being chap'ei
E. 3s2, vol. ia, Laws Of Delaware, pag'
:, 345 4. G. to which said several ac.s u
: Assembly reference is hereby expressly
n made: and that in further pursuance
said combination, conspiracy and agree
i mant the persons aud officers charge,
+ with the duty of executing sucl
d laws have wronGfully and unlawiull.
Murdered. obstructed, prevented and ex
|