H. K. White Statement - Part 1

Q He was there where he could see the books at any time?

A Yes sir, at any time and looked them over often himself.

Q He would often look them over?

A Yes sir, and sometimes he would come into the office and go and take down the book and look at some entry I sup-pose. I did not ask him what he was looking for. He would look at it and put it back again, but regularly every month he would either look over the cash book or I gave him a statement. Sometimes at the last I would give him regularly a state-ment which he filed away I suppose, a transcript of the cashbook, and then he would often take and compare the transcript with the book and place the book up and never say anything.

Q Did he ever make any

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complaint to you about the manner in which you were keeping the books?

A No Sir, not the least.

Q Everything appeared to suit him?

A Yes Sir. He never made any objection to the manner in which I was doing it.

Compare with Lien? [written in margin]

Q What book is that you have in your hand?

A The amended complaint.

Q In what case?

A Ellen M Colton vs. Leland Stanford, Huntington, Crocker & Wells Fargo & Co

Q Where did you get that book?

A I received this in a pack-age sometime in March last. I think.

Q From whom?

A From Mr G. Frank Smith.

Q Where were you as that time?

A I was in Arizona. I think I was at Yuma. I think the the package was for--

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warded to me from Gila Bend. I think it was for-warded to me to Yuma.

Q By G. Frank Smith you mean the attorney of Mrs Colton in this case?

A Yes Sir I suppose so I used to know him by sight G Frank Smith. I suppose it is the same gentleman.

Q Why was it sent to you?

A I requested him to send me the documents or papers in the case so that I could look them over.

Q Did he ask you to look at any particular part of it?

A Yes Sir. not then, but af-terwards he wrote me a letter containing questions for me to answer.

Q Did he ask you to look at any particular part of the complaint?

A No sir. not the complaint.

Q Did he ask you to look at that part of the complaint marked "Exhibit D"?

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A Yes sir. In his letter giving the last questions I think he asked me that question to look over "Exhibit D" and give what information I could upon anything pertaining to that Exhibit.

Q He submitted to you cer-tain questions in writing?

A Yes Sir. I answered them.

Q You answered them; What did you do with you an-swer?

A I sent it to him by mail.

Q To where?

A To San Francisco.

Q Addressed G. Frank Smith San Francisco?

A Yes Sir. No 502 Montgomery Street. I think the Number was I never received any answer to the letter accompanying those answers, from him.

Q Have you been subpoenaed by the plaintiff in this case?

A No Sir.

Q Has Mr. Smith the attor-eny of the plaintiff known

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from time to time where you have been?

A I wrote him several letters. I have written him from three to five letters, only up to pos-sibly two months ago.

Q Have you shown a dis-position or the reverse to attend as a witness on be-half of the plaintiff in this case?

A No sir: I have requested Mr Smith that I might be in attendance, because I wanted to vindicate myself in these matters, and I wrote him to that effect.

Q But he never has called on you to attend?

A No Sir.

Q Did you retain any copy of the questions put to you by Smith and your answers to them?

A No I did not.

Q Have you a copy of any letters that you wrote to Mr Smith?

A I think No Sir.

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