The Abbeville press and banner. [volume] (Abbeville, S.C.) 1869-1924, 1895-01-30
notice, and replying to the specifications
thereof in the order in which made, say as


District. a. c. Latimer" And I allege this
to have been sufficient fully TO inform the
voter that he was voting Tor me 10 represent
the Third District OF South Carolina IN tne
18th Congress Of the United States of Amerl-
ca, for the reason that the election for Repre-
sentative in the 5ith Congress OF the United
States of America was the only Congressional
election ordered or held In tue said Ihifu DIS s.
irict of South Carolina on that date. Ana OF
such ballots / received on the said sixth DAY
of November, 1894. at the various voting pre-
cincts in the said Third Congressional Dis
trict of South Carolina, five thousand seven
hundred and seventy-eight, while you re-
ceived in the said District only nine hundred
and eighty-hve ballots: and the ballots Which
were cast for you contained only the follow
Ing words: "RepreSentativ in F1fty-fonrth
Congress, Third district; Robert MoOrman."
And | submit that IL my tickets were defec-
tive so were yours. There Is nothing on your
ticket to inform the voter that you were
candidate for membership in the 5ith Con-
gress Of the United States OF America from
the Third District Of South Carolina. But l
allege that both your ballots and NINE were
sufficient in form under the laws OF Sou'h
Carolina. .
3. / deny tnat the Board of Canyassers In
each County in said Congressie nal Dlstrlct
had due and legal notice that the baiots cast
for me were illegal by reason OF havlng on i
Congress, Third District; A. G. Latimer;
but ! admit that with or without notice they
counted for me ballots as legal Whlcn nao
and allege that they counted for you, as lie.
val. ballots which had upon them only the
words: "Represertative in Fifty-fourth Con-
grees, Third District; Robert Moorman.
3. As TO the third ground OF speciilcatlon,
wherein you assert that the registration laws
of South Carolina are ain violation OF the
fundamental law and constitution OF lns
State and United States" and lhat the sala
laws deprived you OF six to seven thousand
ballots to which you were entitled, ADMIT
and aver the existence in South Carolina OF
statute law, operative In the CONGRESSIONAL
District aforesaid, and existent since ioe2, pre-
scribing that no person shall be allowed. TO
vote al q general election In South Carolina
unless he shall produce and exhibit TO the
managers of election at the time he oilers TO
vote registration certhcate In Wnlcn his
place of residence and voting precinct snail
be set forth as provided in the said law, with
out which certificate no person, according 10
the said law, is qualified to vote In the salu
state. But l deny that the SAID statutes oi
south Carolina are in violation OF the Constr.
tuition OF either the State or the United
States. And l aver that, If any male cltizen
of The age of twenty.one years or upwards
resident In the State and not convict OF urea
son. murder, robbery, or duelling, was unable
To vote at the said election for want OF prop
err registration certificate, the 1naolilty was
the result of mis- own voluntary act, Inc stat-
utes aforesaid having not only maue d ~ y, 'ne iS
sue q certificate OF registration on due appll-
cation made but having also PROVIDED lo5 az
appeal to the Courts In the event the saio OF
hcer refused to register as req uested. Wheth-
er there were six to seven thousand male citi'
zens above the age OF twenty one years resi-
dent In the said Congressional Dlstrlct VINO
were without registration certificates on the
sixth day of November, 1894, / am unable to
say but deny that such number OF ciliZen,
OF any considerable fraction OF such numoer;
ted themselves at the polls In The salo
District at the election on that
day and offered to vote and were refused the
privilege because they had not registration
certificates. And l aver that the managers OF
the said election did not refuse 10 allow paI-
lots 10 be cast by persons who were the pos
SCISSORS of registration certificates, as by law
prescribed, and who produced the same when
they offered to vote, as by law required.
4. AS to the fourth specification, wherein
von complain th8t managers OF election re-
fused to allow ballots TO be cast on the GROUND
that the parties offering TO cast them had re,
moved from the places In whlch Ihey nVeu
when their registration certncates ,e e,re were le
ton laws aforesaid, and the laws regulating
the conduct Of elections In South Carollna, IL
is the duty OF every person changing MS place
of residence and voting precinct 10 renew nls
Registration certificate If he desire to exercise
the right TO vote In his new place OF reslaehce,
a certificate Of registration, under the sald
laws, being evidence Of the holders qualllca-
tion to vote on ly SO long as he resides at the
place for which 1t was issued. And aver
further that every person VINO was legally
qualified to vote at the election aforesaid anu
who presented himself at the polls Win the
evidence thel eof which the law required, to
wit, proper registration certificate, was al
lowed TO exercise his right without let or him
drance. And deny that the managers OF the
sid election, or any OF them. refused 10 alioW
ballots to be cast by persons who were legally
qualified TO cast them, or that the SAID man
ayers, or any OF them, practiced dlscrlmlna-
ton, obJecting in one instance Rnu iaillng 10
object in another. according as the person
who offered TO vote might be supposed TO In
tend tn cast his ballot for one candidate or lOr
another. f,
5. deny that any person in the Third Con-
gressional District aforesaid VINO was pos
sessed OF a registration certificate which full
filled the requirements OF the law and VINO
produced the same To the managers of eiec-
tion was denied the right TO vote.
6. deny that any person noiding regis
tration certificate and qualified TO vote for
State officers and for members OF the Stale
Legislature was refused the right TO vote at
the Congressional ballot box.
Z. AS TO the seventh ground OF Speelnca.
ton, wherein you charge that supervisors Of
registration denied to voters certlhcates OF
registration without any valid or legal reason
therefor, l deny that the said ofhcers, or any
Of them, in the several counties composing
the Third Congressional District aforesaid, +,
denied certificates Of registration to persons
legally entitled thereto or competent to re-
ceIve them: aud l aver that every person
qualified and entitled under the law To be re-
gistered as voter was SO registered on the
proper application made. And deny that
any legally qualified voter rendering him
sell at the polls and Offering TO vote was re-
fused his right.
your eighth, ninth and tenth grounds OF spec
ificatiou.
Ii. As to the eleventh specification. ad-
m 1t that at I.ongshore's precinct, in the Coun-
ty OF Newberry, one OF the managers OF elec,
ton was at the time trial Justice for said
county; but deny that this disqualified the
the said trial Justice for acting as manager OF
election at said precinct, or IN any way rem
12. l deny the allegations contained IN the
twelfth ground Of specification.
l3. admit that A. E. p. Bedenbaugh, one
OF The members Of the Board of County Can
vnsSers for Newberry County, was. at the
time of tabuIaling the ballots cast for Repre-
sentative To the 5Ith Congress, the Supervi-
sor Of Registration for the County OF New.
berry; but deny that for this reason the tab.
ulation Of the ballots by the said Board OF
CanvaSsers was invalid.
Il. l deny the allegations found In your
fourteenth ground OF specification, and l
Congressional District of South Carolina 10
mem bership In the 54th Congress Of the Unit
ed States of America.
deny that upon the law Of the case there is
Justice or merit In your claim when TO sup
port II you must ask the House OF Represen-
tatives Of the United States TO do SO eXtraor.
dlnary and radical thing as disregard and
override state statutes which in no wise Of
fend or trench upon the constitution or laws
Of the United States, and that, too, when the
said statutes deal with subject which the
said constitution and laws do not touch ex-
cept in so far as they inhibiL 10 a state any
action denying or abridging 10 any of It's citi-
zens the right TO vote on account Of race, col
or, or previous condition OF servitude.
And ] deny that upon the facts OF the case
there is justice or merit in your claim when
to support IT. you must ask the House of Re.
representatives. of the United States TO count as
voters in your behalf men who did not 90
near the polling places on the day OF election.
or offer so TO do, and likewise men who.
though they went TO the polling places, and
neglected 10 provide themselves with proper
registration certificates, condition which
under the law was necessary TO qualify them
to yote-all which persons you would have