Miller - County of San Joaquin vs. Central Pacific R.R.

A --- I decline to answer under advice of Counsel.

Mr. Cohen [underlined] Q 222 --- In your answer in this case page 9, commencing it line 54 of that page you say "The said defendants further deny "that the monies and stocks so as afore "said paid to said Contract and Finance "Company, were in value greatly in excess of "the amount of $206,632,661 50(1/3)/100 or any other sum "of the cost and reasonable profits for "furnishing all materials, furniture and "equipments and doing the work "which was furnished and done by "the said Contract and Finance Company, "under said contract." Will you state what amount of mon [money?] and stocks were paid to the Contract and Finance Company; what was the cost and what was the profit of furnishing the materials, furniture and equipments mentioned in that portion of your answer.

Mr. Sanderson [underlined] --- I make the same objection and give the same advice.

A --- I decline to answer under advice of Counsel.

Mr. Cohen [underlined] --- Q 223 --- How much of the stock of the defendant, the Central Pacific Railroad Company has been issued up to this time.

Mr. Sanderson [underlined] --- I make the same objection and give the same advice.

A --- I decline to answer under advice of

Counsel.

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Mr. Cohen [underlined] I will make an application to the Court to determine how far this examination may go and what are the privileges of this defendant and witness --- and in the meantime, we can agree upon some day to which this can be adjourned.

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An adjournment was here taken until Monday Dec. 13th 1880 at 10 A. M.

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