Evening journal., 1911-01-12

ballots legally cast and legally count
ed for him at said election.
C0unter-Cnarges
Having answered in detail the sew
eral averments contained In the con-
testants notice OF contest, the con-
testee, by authority of the statute un-
der which this contest has been
initiated. sets forth the following
counter-charges to the claims set up
in the contestants notice OF contest,
viz:
% The contestee charges that the
friends and supporters Of the contest
ant and members Of the political
party whose candidate he was at said
election. by the use, delivery and pay
ment Of money, whiskey and other In
toxicaung liquors to a large number
OF qualified voters of the Fourth Rep
resentative district OF New Castle
county, in said Congressional district
OF Delaware, bribed. influenced and
Induced upwards OF three hundred Of
said qualified voters TO cast their bal
lots for the contestant, which said
qualified voters, otherwise. would
have voted for the contestee.
~ The contestee charges that the
friends and supporters of the con-
testant and members of the political
party whose candidate he was at said
election, by the use. payment and de-
livery OF money. whiskey and other
Intoxicating liquors to a large num-
Der OF qualified voters OF the Fifth
Representative district OF New Castle
county, in said Congressional district.
Influenced, induced and bribed up-
ward OF three thousand of said duali-
ned voters to cast their ballots for
the contestant. which said qualified
voters, otherwise would have voted
for the contestee.
(3) The contestee charges that iu
divers other Representative Districts
OF the State of Delaware, In said Con-
gressional District, which said con-
estee is as yet unable 70 particularly
specify, the friends and supporters of
the contestant and members OF the
political party whose candidate he
was, az said election, by the use, pay
ment and delivery Of money, whiskey
and other intoxicating liquors, induc-
ed, bribed and influenced large num-
Der OF qualified voters, the exact num-
ber of whom the oontestee is at pres
ent unable to specify, to cast their
ballots for the said contestant, which
said voters, otherwise, would have
voted for the contestee.
And the contestee hereby charges
and AYERS that, but for the corrupt
practices enumerated in the above
counter-charges INDUCED in by the
friends, supporters and political asso-
ciates OF the contestant, he, the con-
testee, would have received at least
two thousand of the 20.RS1 ballots so
as a aforesaid cast and counted for
the contestant at said election.
Wherefore, the contestee declares
and AYERS that not only is the claim
OF the contestant, that more than
5000 OF the votes which were cast.
and returned for the contestee
were secured by bribery and cor
ruption Of the voters practiced by the
partisan friends and supporters Of the
contestee, mistaken, incorrect, erron-
eous, false and untrue. and not only is
The contestants claim, that the con-
testee was not elected a member of
The Sixty-second Congress from said
Congressional District by a plurality
of all the legal votes cast therein, at
the election aforesaid. incorrect and
untrue; and not only is the contest
ants claim, TO have been elected a
OF the said Sixty-second Con-
gress from the said Congressional dis
trict by plurality OF over 1871 of
all the legal votes cast I'm said district
at said election, Incorrect and untrue;
and not only is the contestants claim
to be legally and justly entitled to a
seat in the Sixty-second Congress of
the United States Of America from the
said Congressional district, incorrect
and untrue; but the contestee claims,
on the other hand, that he Is legally,
lawfully and Justly entitled to a seat
In the said Sixty-second Congress of
The United States OF America from the
said Congressional district; and that,
at the election aforesaid. he was elect
ID and chosen to said ONCE, not only
by a plurality of 2,129 votes, as ap-
peared from the Official canvass OF the
ballots cast at said election, but that
In truth and in fact he was so elected
by plurality OF upwards of 4,129
votes, legally and lawfully cast for
him.
All OF which the contestee stands
ready 10 prove and establish at the
proper time and place.
William II. Heald,
Contestee.
Robert H. Richards,
Robert q HOueton