The Indianapolis journal. [volume] (Indianapolis [Ind.]) 1867-1904, 1897-06-25

Totals . ... 1922 5000 1884 629. "a
During said years your orator was put
to heavy expense on account or litigation
growing out of controversies with the CITY
of indianapolis and the City Railroad Com
pany in relation to your orators right to
occupy the streets of said city for street.
railway purposes, but no part of said eX-
penses are included in the expenditures for
said years above stated, and, although IN
each of said years your orator was re-
quired, as it will be annually hereafter, to
pay the sum of 900 for interest upon its
bonded indebtedness aforesaid, no part OF
the interest so paid is included in the ex-
penditureS so stated for said years.
FARES COLLECTED.
"(c) Your orator further AYERS and shows
that the entire number of fares collected
upon all lof the lines of your orators street
railways during said year beginning May /,
1895, and ending April 80, 1896, was Is, 239. 1885,
which, at cents for each fare, would have
produced revenue of but $577, 1886; that
the entire receipts of your orator from
other sources of said year were:
From postofhce ....................S2 sly %
From advertising Observation-Disclosures. 6OVV.UO
From power rental .................... l,l25.29
so that on the basis of Scent fares, the
entire receipts of your orator from all
sources for said year would have been $751;
72S. 20, being $34, so less than the operating
expenses. taxes and general depreciation of
the property for said year. That the total
pumber of fares collected for the year be-
ginning May 1, 1896, and ending April 80,
1897, was 18,471,527 which, at cents for
each passenger, would have amounted to
1854 1851; that the total receipts from all
other sources during said year We're:
From postoh1ce ..................,....$29 vi, 20
From advertising NEUTRALITY-SUSPICIOUS.. 400. 90
from power rental .................... 1, 4b0. 40
$50 that the total income from all sources
for said year, on the basis of Scent fares,
would have been 62943,22, being $71,6S6.6 2
less than the operating expenses for said
mr.
fact to be- that if said act of March 6, 1897,
be enforced against your orator, your ora
tor will not only be deprived Of the power
to earn by the use of it's property, from
tolls and all other sources, a sum sufficient
to defray the expenses absolutely required
to be incurred in the maintenance and OPP
GRAFTON of said property, but that your ora
tor will be deprived of any income or re-
turn whatever upon the value of its prop
erty, exclusive of the franchise of operat-
ing said street-railway system, owned and
used in connection with the said street rail-
way system, and which your orator can
make no use of, except for street-railway
purposes in connection with said system,
and your orator further AYERS and shows,
that no dividends whatever have been paid
to the stockholders of your orator since
the year 1892.
Wherefore, your orator AYERS and
charges that the enforcement of said act
as against your orator, will deprive and
take from your orator its property without
due of Law and tnd IN as sad
ways in cities having a population of 1OO,O 900
or more according to the United States
census of 1890, and the city of Indianapolis
is the only city answering to said descrip-
ton, wherefore said act cannot apply to
street-railway companies in cities which
may hereafter attain population Of 100, 900
or more, it's enforcement denies to your
orator the equal protection of the laws, all
in violation Of the aforesaid amendment to
the Constitution of the United States"
The next paragraph OF the cross-bill de-
clares that the act violates contract be-
tween the company and the State and that
it violates the State Constitution. The next
and closing paragraph seeks to bring in as
parties the persons who have sued the COM
pany under the 3-cent-fare law.