The farmer and mechanic. [volume] (Raleigh, N.C.) 18??-19??, 1900-11-27
THE COMPLAINT AND ANSWERS.
Charges by Mr.. Gattis. Replies by DR.. Filgo
and Messrs. Duke and Odell.

For a proper understanding OF the
Gattis-KilGO libel suit now OF trial at
Oxford, a reading Of the formal COM
plaint and answers is necessary. Iney
are as follows:
COMPLAINT OF REV. I. ]. GATTIS.
The plaintiff complains and alleges as
follows. to-Wit:
l.. Tha1 he is now, and has been for
many years last past, a clergyman and
minister of the gospel and a member in
good standing of the Methodist Episcopal
Church South, and all his lifetime here
tOfOre has been a good, true, honest and
law-abiding citizen of the State of North
Carolina, and as such has conducted him
self, and until the alleged commission
of the alleged grievances and offences,
hereinafter mentioned and charged
against him by the defendants, the plain
tiff was always reputed to be a person of
good fame and credit, and has never been
guilty, nor until the alleged commission
of the alleged grievances and offences
hereinafter mentioned, been supected to
have been guilty of the alleged griev-
ances and offences hereinafter mention
ed; by means Of which said premises,
he, the said plaintiff, before the alleged
commission of the grievances and Of
lkliS1o a. u1S1i NS'iI NtAl oIu IL
joyed the good opinion Of his neighbors
and of all other persons to whom he was
known.
2. That at the times hereinafter men
toned and referred to, the plaintiff was
a member of the business firm or part
nership of T. j. Gattis & Son, Durham,
North Carolina, doing business in the
purchase and sale of religious books and
literature, under the auspices of the
North Carolina Conference and the South
Caroline Conference of the Methodist
Episcopal Church South, and in the pur-
chase and sale of other books and arti-
cles of merchandise usually kept in a
bookstore business.
8. That in the month of September,
1898, the defendants, John c.. kilgo, Ben
jamin N. Duke and William f. Odell pub
lished or caused to be published in Dur
which contained the words hereinafter
set forth.
4. That in the month Of September,
1898, the defendants John c. Kilgo, Ben
jamin N. Duke and William R.. Odell, will
fully, WantOnly, unlawfully and mali
ciously, contriving and Intending to in
jure the good name and reputation of
the plaintiff and to bring him into public
scandal, infamy and disgrace, and to
heap ridiculc, disgrace and contempt upon
him in his sacred calling, and to impair
his usefulness and influence. and to in
Jure, and if possible destroy the business
i'll which plaintiff was then engaged. COM
posed and published, and caused to be
composed and published in the county of
Durham, and to be extensively circulated
and read in the county of Granville. and
in other counties of North Carolina, a GER
tain printed pamphlet purporting to be
a Report of the proceedings of the in
veStiSatlon of the charges by Justice Wal
Ter Clark against DR.. John C. Kilso. pres
lcent OF trinity College, Durham, n. c..
made by the Board Of Trustees of Trim
lty College, August 80 and 81, 1888 in
which said printed pamphlet were com
| posed and printed and published of and
concerning the plaintiff, the following
false and defamatory words contained in
said printed pamphlet, published and cir
culated and read as aforesaid. that is ia
say, as follows:
You recall, gentlemen. that in the
defendants first correspondence with
Judge Clark. the Judge demanded that
President Kilgo give him the Information
The defendant did SO at once. But. gen
tlemen, If you will take the whole sit,1a-
ZION and connect it with the testimony
OF Mr. Gattis (meaning T. I Gattic ~
plalatl1l In this action, you will likely
ma the original slanderer. Here are the
facts: Mr.. Gattis (meaning r. ]. Cat
lis the plaintiff in this action, said he
was tut on the stand against his win
mat ne did not wish to come here. that
ne was pressed to come: that no had
rather siFe one hundred. dollars and be
out OF IT, That is a high price for him
ina' means that an ordinary man would
naNe gwen a very large amount for a
> h''ie oo""oolty. Behind a pious smile,