The Saint Paul globe. (St. Paul, Minn.) 1896-1905, 1902-09-02
FILE MERGER
SUIT ANSWERS
Continued From First Page.

| Sohtinued from First Pages
| er, or that they have ever been COM
| peting lines except at few points, at
nearly all of which points they COM
peted and still compete with the lines
OF other railway companies; and 1t
denies that said defendant railway
| companies have at any time competed
with each other for passenger or
| freight traffic in any other or different
manner or to any greater extent than
| they have continuously done since the
! formation of the Northern Securities
| company, and will continue to do in
| the future.
1t admits that the lines of said de-
PENDANT railway companies are the only
| lines of any single railway company
| trayers1ng east and west all the north
| ern tier of states of the United States
west of the Mississippi river. But it de-
MES that said lines are the only lines
crossing the state of Minnesota and
connecting the Pacific ocean by rail
with points in said state; or that they
are the only lines connecting the ter
ritory Of said northern tier of states
or the territory tributary thereto by
rail with the Pacific ocean. And 1t
denies each and every statement in
said subdivision w. of said bill con-
| tanned not hereinbefore expressly adj
| mitted.
Regarding Land Grants.
| 1t admits that large quantities of
swamp lands were granted by the
United States to the state Of Mime
! sofa by the acts of congress mention
ed in subdivision " of said BILL for the
! purposes in said acts set forth. But
it knows not, and has not been inform
/ ed save by said bill, and cannot set
forth as to its belief or otherwise, as to
| what quantity, If any of said lands,
are now owned by said state, nor as to
the value. If any, of such lands or any
OF them; nor to what extent, If at all,
the value or STABILITY of said lands, or
any Of them, depends upon competi-
| ton of any kind between the said de-
PENDANT railway companies, or upon the
construction Of railway lines by both
or either of said defendant railway
companies.
viii Continue Branch Buildings.
1t admits that each of said COM
panies has heretofore, and as the cir
cumstances of each case warranted,
| from time to time built spur or branch
lines into territory adjacent to it's rail-
| way as well as into new territory; but
| 1T denies that such construction has
been by reason of rivalry between said
companies, or that the construction of
such spur or branch lines has been or
will be prevented, or lessened, or defer
red, or in any way affected by the for
nation Of the Northern Securities COM
pany. And it denies that the matters,
or any Of them, alleged in said bill
have prevented or hindered, or will in
| the future prevent or hinder, the con-
| struction by the plaintiff, or by any
person or corporation thereto author
! lied by plaintiff of any line or lines of
! railroad that the plaintiff may deem
| necessary or advantageous to bring It's
i swamp lands into market and secure
their settlement and occupation.
| 1t denies each and every allegation
| in said subdivision " of said bill not
| herein expressly admitted.
| 1t admits the plaintiffs ownership,
maintenance and operation of the inSti-
| buttons named in subdivision vi. of
said BILL and that small portion and
no more Of the supplies for some of
| said institutions requires to be and Is
! III fact carried over the line Of one or
the other of tn, defendant railway COM
| panies. AS to the other matters stated
| in said subdivision VI, this defend
| ant knows not, and has not been in
formed save by said bill and cannot
| set forth as to its belief or otherwise
| in respect Of said matters or any Of
| them.
| State Never Owned Lands.
1t says that except the grants of
| swamp lands mentioned in subdivisions
VII. and VIII. of said bill, the grants by
plaintiff in aid Of railways in Mime
sofa mentioned in said subdivisions
| We're made by the territory and state
Of Minnesota merely in execution of
| trusts reposed in them respectively by
! acts of congress granting lands of the
| United States to aid in the construction
| of such railways. None of said lands
were ever the property of said terri
| tory or state, each of whom was mere
| conduit to transfer the title of such
| lands from the United States to the
respective corporations by which such
| railways We're built; and said grants,
! whether congressional, territorial or
| state, were solely in consideration Of
the construction, and not of the main
tenance of such railways, and none of
said grants were made to either Of the
| defendant railway companies. None of
such grants nor either of said swamp
| land grants was a gift to the COM
pany receiving the same, but each and
| every OF them was made upon a valu-
! able and full consideration fun nished by
| the company receiving the same. The
st. Paul, Minneapolis & Manitoba Rail-
way company, lessor of the Great
Northern company as this defendant is
informed, purchased and paid full VAL
! lie for all the lands acquired by 1t from
! its predecessors under grants made
| to them.
This defendant purchased and paid
| full value to its predeces sors for all
| the lands in Minnesota referred to in
| the bill as belonging to it, and neither
! this defendant nor it's predecessor the
Northern Pacific Railroad company
ever received any grant of lands from
| SAID territory or state except the grants
| of swamp lands mentioned in said sub
| divisions VII. and VIII, which grants
| of swamp lands were made in consid-
! Grafton OF the construction only, and
| not OF the maintenance, of the lines in
aid tf which they We're respectively
made, and said consideration was long
since fully performed.
| AS to the total amount of grants
! from the public domain Of the United
| States to aid in building railroads In
Minnesota, this defendant knows not
! and has not been Informed save by
said bill and cannot set forth as to
| it's belief or otherwise. But it says that
| besides the grant made by congress
| directly to the Northern Pacific Rail-
road company in that company's char
! ter, grants were made by congress,
| through the medium of the territory
and state of Minnesota, for many 9TH
er lines of railroad than those operat-
ed by either of the defendant railroad
companies, and to an amount far in
excess Of the grants for said lines of
said companies.
Rates Are Not Higher.
1t admits the making Of large ship
ments Of wheat and other products and
of merchandise from and to the places
named in subdivision TX. Of asid bill.
1t denies that competition between the
defendant railway companies for traf-
fic between said places or any of them
was, prior to the organization of the