Evening journal., 1911-11-14
TROLLEY co.
MAKES REPLY
Additional AffidavltS Filed
Refute Utilities Commits
SIGN Position
SAY HOFF VALUATION
FIGURES ARE LOW

The Wilmington and Philadelphia
Traction Company. through its at
torneys. late yesterday afternoon,
filed aiIidavits in the United States
Court. in reply to the affidavits filed
by the Board Of Utilities Commission
ers recently, in the strip ticket fight.
The afidavits we're submitted by
President Crosby, Of the traction
company. General Manager William
A. Heindle. Carroll A. Bailey. John
n. Shannahan and Charles n. Ryan.
In his affidavit Mr.. Crosby refers
to the fact that he had sworn to the
sum of S2500,000 as a reasonable
physical valuation OF the said proper
ties. and he goes on to say that Il
was not intended to mean strictly re-
placement value, nor strictly the total
capital investment but as a phrase
intended to express the approximate
cash cost of producing the properties.
Mr.. Crosby also gives rather
lengthy recital of his career from
the time he graduated from the
United States Military Academy and
entered the army engineer corps up
to the present time, and among other
things he calls attention TO the fact
that he is Joint author Of Crosby and
Bell or the Electrical Railway in
Theory and Practice"
with respect TO the affidavit OF s
;. Hon, who was general manager OF
the Wilmington City Railway Com
pany, Mr.. Crosby declares that he
never heard of a request made of Mr..
Hon for an estimate o. the cost OF
Improving the property and that no
such figure as S250,O00 was ever re-
ported to him.
The substance Of the other aff-
davits Is to the effect that Mr.. Hon
VINO was asked to make an estimate
Tor the utility commissioners as 10
what IL would cost to replace the
property with entirely now material.
named an amount insufficient. Mr..
HON estimated that the property
could be replaced for total os
N,43O, ,260.40
General Manager Heindlc. i'm his
affidavit, refers to the fact that he rs
a graduate civil engineer and has
been manager OF railways OF the local
concern since July ! Of last year. He
says he is familiar with all the lines.
and that Mr., Hoffs statement is in
correct and that the sum he gave as
his estimate is insufficient. He con-
tends that Mr.. Hon made no allow
ance for bridges or culverts, and that
the cost Of replacing the properties.
not including the large but indefinite
amount for fixed or overhead charges
necessarily incident to the replace
ment OF such properties would closely
approximate S2000,000. He expressed
the belief that the abolition of strir
tickets will result I'm increased rev.
enuc.
Carroll A. Bailey's affidavit is to the
! effect that he is an electrical engi-
neer and for the past IL years has
been employed by the J. G. White and
Company, Inc, and he believes that
! S44l 900 viii be required by these
properties within the next few years
to put them in reasonably salts
factory condition for additional oper-
alton.
John N. Shannahan, a civil engi-
neer employed by White aud Com
pany, holds that the statement of Mr.
Hon Is insufficient In his Judgment
the cost of replacing tracks would be
Sl4S,000 greater than the amount
shown by him. He thinks straight
fares mean increased revenue
Charles n. Ryan, auditor Of the
company, makes an affidavit to the ef-
feet that at one time he was assistant
treasurer Of the Pottsville Union
Traction Company, and he gives fig
ures to show that the loss of revenue
for thirteen months when strip tickets
were sold was at least 14,S35.S4.