Fort Worth gazette. [volume] (Fort Worth, Tex.) 1891-1898, 1893-05-24

not in making purchases VI stock. Ia,
h motive 10 ipinrc any other stock
Thlry-seventh, Further answering snia
Fnupn defendant StAtes said PAGE In.
peen very soliritnus abont the interest -,
SAID stockholders and has NON lime H.
,lnio' when defendant hank ne,sle1 4
inr'id' advanced large sums 0f none,
anu endorsed the paper Of The bank Al
enable u 10 tide over difficulties mud for
hr sake OF preventing lass 10 the bank.
* creditors and sloekhollers: that Snid
rage has kept gu deposit ~ said hank
tho sun OF from SlO.O,n 10 StOuOO, tinf
ne has loaned his name and cr4lii ~
s'lI bank - the cytcnt OF Susanna
ihirty-eighth. Further answering said
pcltlon defendant says that It u not true
az therein alleged that the active naun -.
ment of said bank is conducted bv said
Rage aud smith: and that Ii is not true
~ therein alleged that said Smith and
rage arc cunspifiug and confnderatinr
together for The purpose OF enabling sai1
rage 10 carry out any design to injnre
the stockholders or creditors nf said bank .
ANA are so managing the affairs of said
bank as to aid and assist said Page In
uiesaccomnlisliment Of any such purpose;
and that It is untrue that said A. p
Lnckett is merely nominally president Of
said bank, the fact being that said
luclett is actually aud actively the
president Of said bank and has been and
y now performing valuable services IN
behalf of said bank ~ will be hereinafter
more fully stated. aud that nothing h
done IN managing the aifaifS OF said
bank by said Smith and Page or either
Of them without the authority and con,
currcnce OF the directors.
Thirty ninth Further answering said
patiton, defendant denios that the pres
cnt management Of the said hank Is
being conducted Mt an cXorbitant. uu-
nrS~sary AMI useless expense; that
Il Is true as stated In said petition that
\, II. smith Is paid $500 per month
for acting as cashier, that A. =, Luckctt
Is paid 500 per month for acting ~
president and that George Mnsde ~
puid SiU0 per mouth FOR acting m book
keeper, and that the further sum Of
$3.50 per mouth Is paid for rent but
defendant alleges that said salaries aud
expenses are all reasonable aud proper,
that when said bank suspended bust
ness IN July, 1871, aud when Il resumed
business in September, 1891, there was
due to Il very large sum Of money,
amounting at the former date TO the
sum OF Sl2i2, 2Oi 90. and ut the latter
date TO the sum OF Sl,Wi2, 2Do.A, due
from large number Of persons. that
said debts 80 due the bank were
contracted during the time said Smith
was It's cashier, aud at the time of it's
suspension and resumption Of business
SAID Smith lNsscnscd knowledge Of
thr facts relating TO said debts not p0-
sesspd by any other person; that Ut the
TIME of said suspension therr existed
aud from then nntil now there has
existed great stringency 10 financial
matters IN this section of the country,
rendering the collection of any debts
extremely dihicult: that many Of sJid
debts were contested md agc now bit
terly contested In the courts OF the
conntry thnt at the time Of said sus-
pension and resumption of business by
said bank 1t OWNED n large sum of
money, to-wit the sum nl S0l5,3Sl2l
at the former time mud the sum Of
Suti13Si - a the latter; that when IL
incurred said Indebtedness said Suith
was It's cashier aud knew the facts con
corning aid Indebtedness, which con
sisted OF large number OF demands
due to a large number Of persons, and |
III 4 no other person was 10 inmliar
with the fac.s relating 20 the collection
OF said dehtr due by said bank Az said
smith; that for all debts due to said
bunk there were soeudlies of various
kinds. some debts b ing secured BY per
-onal endorsement, some by eolllteiils
deposited with the bank. and some 10y
Hens on properly,
That said Smith md 10 other person
eurity for said debts, that the presence
VI said Smith In said bank after ~ re
SUMPTION and his connection with u as |
cashier have been absolutely essential |
In order TO the collection Of said debts,
and especially such Of them as wore con
tested: that his undivided attention Inns
been necessary In the enforcement nnd |
attempted enforcement Of the collection
said debts, and in orlrr tn the aHcet-
VI the correctness 0t the tt-
uauds due by said hAuk and fhuir pas
urnt. that said Sinith had for many
'rafs prior TO the NlsNnsion and resunp'
ION Of business hy said hnnk been d bank
, highly accomplished expert In that
'annrify and he was universally recug-
ilEcd ~ a safe, reliable mud honest bust
eiss man aud cashier; TINT the rpspon~i'
,ility and labor necessary IN ana about
he enforcement Of tho collection OF debts
he to the bank and In and about the ex-
and payment OF M debts due
N the bank. were TOO great for amy one
mn aud that therefore Il was necessary
Int sone one he employed Ia assist said
'miih IN the management OF said mat
,rs; that accordingly Luckett, who was
N pXpprienced business man, extensively
rqnniutcd with the people ill this COM
unity aud especially those indebted to
aid bank who WIS and Is Il man Of IRE.
ronchable character and who was, aud
peculiarly adapted 20 the task Of com.
ding the payment Of debts, wis selected
+ president Of said bank: that since his
with said bank NJ president
!. las been constantly cooperating With
aid Smith Ia. attending 10 The affairs
/ said bank. and bis services have been
1solutely essciitinl,
That It has been necessary, the mat
RS being numerous and complicated
nd involving many thousands Of dol
.rs. to have competent bOok keeper
keep the books Of said bank since It's
sumption Of business. aS aforesaid,
mt for the performance Of said work
III tie0rge AIassc has been engaged
adj his services Ia that capacity have
nee his employment been constantly re- {
iired thar he Is a suitable person for !
n work committed 70 him. being an
hcisri hOokkeepcr aud man Of high
aracter. that By reason OF the COM 4
icaton Of the Affairs Of said bank 4
Vi they are exceedingly Intricate pftcr 4
! resumption Of business. hone but com Il
tent business men should have con- \
lrtcl ia operations AMI no two men so a
III qualified for the nrduOns duties Il
The position could have been obtained c
r smaller salaries than have been paid o
NTH and Iurkeit. and for the import Il
L matter Of keeping the books no per- Ii
D could have been procured Ut n less =
Larry than has hera paid said Massic. a
Al iu the cmploymfut Of sail Smith AZ I.
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