ENPages
AlfredACohen006
the complaint?
A. All the knowledge I had on the subject of the defendant's having purchased it, except I had heard so before.
Q. 23. From whom?
A. Well, I think from Governor Stanford, or Mr. Hopkins. It was a general talk among the directors of the Company. I cannot remember which one spoke of it.
Q. 24 When did Governor Stanford tell you so?
A. It was along about the timie [time] the purchase was made. It was talked of generally among the directors of the Com-pany, and I understood at that time that the defendant made the purchase for the Company; but which one or who said it I cannot now remember
Q. 25 What time was that, Mr. Miller?
A. I cannot fix the date. — Either in 1869 or 1870: I don't know which.
Q. 26 It is important to determine which.
A. I do not know of anything by which I can fix the date.
Q.27 In what relation was that conver= =sation had between you and the directors of the Company?
A. It was in relation to general talk about the purchasing of the block, and
5
AlfredACohen007
the necessities of having it.
Q. 28 Let me ask you: What was the first transaction had by the Company in relation to that block?
A. The first transaction, so far as my know= =ledge is concerned, was in paying rent for it.
Q. 29 Was that conversation had before you commenced to pay rent?
A. No: after we commenced to pay rent.
Q. 30 Was that conversation had before you took the privilege of purchasing the prop= =erty, or after?
A. I did not know anything about the taking of the privilege of purchase of it. It was sometime after we commenced to pay rent
Q.31 How long did you pay rent for that property?
A. I cannot recollect.
Q. 32 Was the purchase of the property made in any way through your department?
A. No.
Q. 33 Did you have any communication with the defendant concerning that purchase?
A. None.
Q.3 4 Not in any way?
A. No: — At least, none that I remember. I am quite sure I never had.
6
AlfredACohen008
Q. 35 How long after you commenced to pay rent was it before one of your Companies purchased the property?
A. Well, of my own knowledge I cannot now remember. I do not remember, but I think within a year.
Q.36 It was within a year?
A. I think so.
Q.37 Was that conversation which you had with the directors about the time the purchase was made, or about the time you commenced to pay rent?
A. I do not remember, only that is must have been after we commenced to pay rent. This is all the time I can fix.
Q.38 Did Governor Stanford tell you that the property was purchased by the defend= =ant for the Company?
A. I do not think it was stated in that way: I do not think it was a positive statement of that kind. It wa a gen= =eral talk. I so understood it.
Q.39 Well, as nearly as you can recollect, what did he say about it?
A. I cannot remember anything that he said.
Q.40 Did you ever have any talk with C. P. Huntington concerning it?
7
AlfredACohen009
A. Never.
Q. 41 Do you know when the purchase of block 9 from Mr. Tichenor was made?
A. I do not
Q. 42 Do you recollect what you have averred in your complaint concerning it?
A. No.
Q. 43 You do not?
A. I do not recollect positively.
Q. 44 As nearly as you recollect, what was your averment in the complaint concern= = that purchase?
A. I have very little recollection about it.
Q. 45 Who are the gentlemen you have spoken of, from whom you derived your information: Judge Sanderson and Judge Robinson?
A. They are the counsel and attorneys for the Company.
Q. 46 Is the Robinson you speak of the venerable judge, or the younger gentleman of that name?
A. He is the most venerably of the Robinson family.
Q. 47 I believe you are a director of this Company?
A. Yes sir.
Q. 48 How long have you been a director?
8
AlfredACohen010
A. About twelve years. I think.
Q. 49 Are you also a stockholder?
A. Yes sir.
Q. 50 Have you been a stockholder all that time?
A. Longer.
Q. 51 You took no part, then, in the pur= =chase of this property, either as director or as secretary of the Company?
A. None whatever.
Q. 52 What corporation is this spoken of in the complaint as acting as agent and trustee for the Company in the purchase of that property?
Objn. Mr. McAllister: I object to that ques= =tion. You cannot examine as to the con= =tents of a written paper without handing the paper to the witness and letting him see what the paper is.
A. The Contract and Finance Company.
Q. 53 Are you a member of that Company?
A. I am not.
Q. 54 Have you ever been?
A. Never..
Q. 55 At whose request did the Contract and Finance Company act as the trustee for the plaintiff in this purchase?
A. I do not know.
Q. 56 What was the nature of that trust?
9