The Democratic press. [volume] (Ravenna, O. [Ohio]) 1868-1901, 1892-08-10

Three weeks ago we published the substanc
of petition in the Common Pleas Court filed
by 1. G. Nahkin VS. w. j. Hayes in which certain
allegations were made upon which the plaintiff
bases claim for Sl067.37. At that time the an
swer of Mr.. Hayes had not been filed, and we
were therefore unable to acquaint our readers
with the defense set forth by that gentleman.
which we now have the opportunity of doing.
The substance of the pleading is as follows:
The defendant admits that he is the owner of a
farm situated in Ravenna and Rootstown town
ships; admits that a result of certain nego-
tiations between himself and plaintiff, he did
write letter to the latter about March 28th,
1891, which has been labeled, copy of contract
filed with petition and made part thereof De-
fendant says that he has made outlay of very
large amount of money on his farm. running up
to many thousand dollars; that the said farm is
and has been for several years under full culti-
walton and development; that he owns and
keeps for breeding for dairy purposes a very
high grade of cattle on said farm that his farm
is mostly completely equipped with all modern
implements and machinery; that connected with
his dairy he operates creamery of modern i'm
provement; that plaintiff knew all this, and yet
falsely represented that he was person of great
ability and experience in the management of
farms and establishments of this kind and
that defendant. relying on these statements. did
agree to pay him the large salary named in the
letter above mentioned. Defendant further ad-
mits that the plaintiff entered his employ Feb
ruary 4st. and that he discharged him about
June 1st, but that he was justified in so doing
because plaintiff was entirely. and utterly and
continually incompetent to discharge the ordin-
ary duties in and about his said employment {;
| that by reason thereof he hired more farm hands
than were necessary that he absented himself
without leave, for days at time. carrying on
his own private schemes and enterprises. making
no provision for the management of the farm in
the meantime that he attempted to defraud
and cheat the defendant by obtaining a profit
for himself in purchases made as agent or SER
want of the defendant, for repairs and articles
| for use upon said farm that he refused and was
tardy in carrying out the reasonable instructions
given him by defendant; that while he had ev-
erything at his command to do so, he was habit
ually guilty of neglect in his ordinary duties on
the farm that he permitted the stables and hen
| houses to become filthy and the animals lousy.
scabby and NANCY, Defendant further says that
the plaintiff contrary to his instructions bred a
certain high bred heifer calf 10 months of age
that the defendant is the owner of high register
ed bulls, bought and kept for the purpose Of
| improving his stock. but that plaintiff bred
many of plaintiffs COWS to inferior stock when
he should have bred to the aforesaid bulls. thus
degrading the offspring. to the great damage o.
the whole herd that in other cases he failed to
breed his cows at the proper season, so that they
are now not with calf. and that by neglect th'
] cattle became lousy. NANCY and diseased. The
defendant denies any Indebtedness on his part tt
the plaintiff. and asks judgment against him by
| Al l., ,A.la ca-AL -
81 200. Holcomb & Beckley represent the de
/ tendant