Evening journal., 1911-10-27
AFFIDAVITS
GO TO COURT
Trolley Co. Shows Hand In
Fight Against Strip Ticket
Order
UTILITIES COMMISSION
WILL REPLY BY NOV. s

ment made by President Crosby. Of
that company yesterday, that atfidav-
its in support of the motion made in
the United States Court. for pre-
liminary injunction and restraining
order. directed against the Public
Utilities Commission in the strip
ticket case would not be filed yester-
day. they were filed with the clerk of
that tribunal late in the afternoon.
Ward. Gray and Neary, counsel for
the company, filed the affidavits which
were furnished by John A. Rigg,
president Of the Interstate Railways
Company: Oscar r. Crosby, president
Of the Wilmington and Philadelphia
Traction Company; Henry p. Scott, a
director OF the local company. and
Charles G.. Guyer, the stenographer,
who took testimony at the meetings Of
the Board OF Utilities Commissioners
The defendants in the case now
have until November 6 to file affdavits
in reply to the traction company. The
company then has until November 13
to file additional affidavits. The argu-
ment on the motion for preliminary
injunction will then be heard by the
court on November 16.
The affidavits of President Crosby
and Director Scott are lengthy and
contain figures relative to the finances
Of the company tending to show the
necessity Of abolishing strip tickets.
Mr.. Guyer's affdavit merely recites
report of the proceedings before
the Board Of Utilities Commissioners.
and the affidavit of Mr.. Rigg takes
up the cases OF the old companies
with respect to interest charges, etc,
under the terms of the lease.
The affidavit Of Henry p Scott sets
forth that he is a director of the Will
mington and Philadelphia Traction
Company. and IL further relates 20
the action taken by the Utilities Com
missioners He expresses the belief
that the statement OF President
Crosby of the company. with respect
10 the gross earnings for the year
ending July /. 1911, of the companies
in Wilmington and vicinity, Is correct.
He further AYERS that since its or
ganization the company has expended
out OF its capital about 100000 In
Improvements to local property and
that OF the Southern Pennsylvania
Company: that the Wilmington and
Philadelphia Traction Company has
borrowed the sum of 100000 for the
purchase Of new rolling stock. and
that II must eXpend further large
sums to put its property In a good
and efficient state Of repairs for the
betterment Of service. He speaks oi
the paving which the company has
In. a a. 40 A. ~
says that during the year ending Jul,
J. 1911. such paving and repavinl
amounted 10 upwards of $4,000; tina
for grading and paving next year thu
amount will likely he 100000.
Mr. Scott states that under sensi
bic method of financing railway sys
TENS there should be taken into ac
count the annual depreciation ri
trackage. overhead work. rolling
stock, etc, and he continues, by say
ing;
"The power TO borrow money fol
such purposes has limit which Is
eventually reached and is being near
~ approached at present by the rail-
way companies complainant in the
bill of complaint"
Mr.. Scott expresses the belief thai
before the making OF the leases by
the lesser companies. they we're strug
CLING with the financial problems o
paying operating expenses, interest
ETC.: that they were only able q
cope with the problems during III
ten years prior to July /, 1910, by Dor
rowing large sums of money fron
certain holding companies interested
and even then physical condition
were run down He AYERS furths
hat "the experiment conducted 70
ten years of selling six tickets for
quarter In connection with straigh
fares has been ineffective Z
adequately increase patronage Of Il
railway lines by the public of tn
community OF Wilmington"
Mr. Scott goes on to speak of tn
increases in wages given employel
and he states that the plan to abolis
strip tickets was contemplated by tn
old company. but az the request 2
persons organizing the Wilmingto
and Philadelphia Traction Compan
the order was withheld i'm order I
give a further trial Of the sale q
strip tickets under conditions Of i'm
proved service At the end Of on
fNHi IT. Wnn A'nhh NNhl q tai t'i AN
come was necessary and the ticket
were abolished
The AFFIDAVIT of President Crosb
hrst takes up the action brought bs
fore the Utilities Commission and dC
clares that the company was deprive
Of proving its charter rights. whic
was its main defence. and therefor
he contends that the order of III
Utilities Commission in ordering n
sale o. strip tickets restored was /
legal. He reviews the organization
the company and of the failure
strip tickets to provide sufficient II
come. He gives the financial cond
tion resulting from the operation
the said leased railway lines in Wi
mington and vicinity for the ye;
ending July 1. 1911, as follows:
Gross receipts for the year endir
July /, 1911. S553.e4467; amounts e
pended during the same period. S4Sl
1851: remaining for depreciation al
interest charges and surplus al
special charge, $66,445.96: pro ra
OF discount on reissue of $500 900.
Wilmington City Railway Compa
bonds upon new mortgage, Stops
balance, S56,159e6: interest on o,
standing mortgages. $4,000; inter,
on $4,000 outstanding mortga
bonds OF the Wilmington and Ed
Moor Railway Company, $50 900: b
ance, s12,159; rentals, $113,0Ss.49;
fcencv eunnlied nv new capf,