The Manning times. [volume] (Manning, Clarendon County, S.C.) 1884-current, 1902-01-29
PRESENTS IT'S SIDE.
The Virginia-Carolina Company Re.
plies to the Charges
OF THE ATTORNEY GENERAL.

CF THE ATTORNEY GENERAL.
Ar Able Presentation Of It's Side Of
n" Controversy Which II Wants
the People to Read ana
Think Over.
The defendant. the Nirginia-CarOli-
na Chemical company. most respect
fully shows that this cause has by the
fling Of the petition and bend for re-
moral herein. been duly removed to
the United States circuit court for the
eastern district of South Carolina. and
that this honorable court has no fur
ther jurisdiction thereof: and this de-
fendant. in no wise admitting TO the
jurisdiction Of this honorable court.
but protests against the same and an
swerin@ herein because Of the proper
respect due to this honorable court.
should it Notwithstanding said protest
ahjudgc that it has jurisdiction of this
action. and order that the same pro-
coed herein. Now this defendant for
answer to the complaint and amended
complaint herein alleged:
FirSt-It admits the allegations Of
the first article Of tie said complaint.
Sccond-It admits the allegations OF
the second article OF the complaint
saving and excepting it shows and al
leges that under and in pursuance OF
the public laws of the State OF South
Carolina. it located and carried on
business within the State o. South
Carolina, as to such part Of its business
as was properly to be transacted there
in. long prior to the 2nd day OF Janu-
airy. 1900. and further alleges that un-
der its charter and the laws OF New
jersey. it is empowered to purchase,
acquire and hold stock in the corpora
tionS, domestic and foreign.
Third--It admits the allegations of
the 3rd, 18th, 5th, 9Th. seventh and
eighth and ninth articles Of the said
complaint.
Tenth-It answers to the allega-
tions OF the tenth article OF the COM
plant, this defendant admits the pas
sage by the general assembly OF the
State of South Carolina Of the acts
therein referred to. but shows that
the same are but partly in said article
set forth and alleged, and prays refer
ence by this honorable court to the
said acts in full for their provisions.
ElevenUh-It admits so much of ar
ticle eleventh Of said complaint as
may be held to allege that all the de-
PENDANTS in the said complaint men
toned were enterior to the time and
date OF the sale and transfer OF the
respective properties Hereinafter men
toned, engaged in the manufacture
and sale Of fertilizers in South Carroll
ma. and denies all other allegations in
the said article set forth.
Twelfth-It denies each and every
allegation contained in the twelfth
article OF the said complaint.
Thirteenth-lt denies each and
every allegation contained in the thlr-
teenth article Of said complaint. save
and excepting that this defendant ad-
mits the conveyance to itupon the re-
snective dates mentioned in the said
thirteenth article of the property end
plant Of the said several respective
fertilizer companies therein mentioned
for the consideration therein set forth.
Fourteenth-It denies each and
every allegation contained in the four
teenth article Of said complaint.
Fifteenth-It denies the allegations
of the fifteenth article Of the said COM
plant, this defendant admits
save that for the purpose of
supplying necessary raw material, to
wit: Phosphate deposits containing
a sufficient percentage Of bone phos-
phate of lime, it has acquired and
owns a certain amount Of land OF phos-
phate territory in the State of South
Carolina, but no more of the same than
is reasonably proper and sufficient to
supply the necessary properties OF TINS
defendant in the manufacture ard
output Of its fertilizers. This defend
ant admits further that for the pur-
pose of securing and supplying to this
defendant of chat ingredient in the
manufacturing CT complete fertilizers
known as nitrogen which is the most
essential ingredient, therein. it ac-
Quired large amount Of the capital
stock Of the Southern Cotton Oil COM
pany. That the said Cotton Oil COM
pany. is not d competitor in any way
OF this defendant in manufacture and
sale of fertilizers, but is simply the
purchaser of cotton seed, wherefrom it
manufactures cotton seed Oil anG
the cotton seed oil products.
as well as the cotton seed meal from
which the ingredient Of nitrogen as
furnished is auxiliary and assists the
manufacture and sale OF the complete
fertilizers. and that the procuring Of
said cotton seed meal in like manner
as the procuring OF phosphate rock is
simply auxiliary and assistant in the
manufacture of complete fertilizers.
Sixteenth-This defendant denies
the allegation of the sixteenth article
Of the complaint.
Seventeenth-This defendant in an
swer to the allegations OF article sew
enteenth Of the said complaint denies
the same except and save that this de-