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Proceedings and Debates of the 1867 Constitutional Convention
Volume 74, Volume 1, Debates 14   View pdf image (33K)
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quired any argument from the defendants' counsel he
would notify them, otherwise he would decide the case at
once, when the complainants' notes had been considered.
ANSWER OF THE POLICE COMMISSIONERS.
The following is the answer filed by Mr. Wallis, the
counsel for the Police Board, to the bill for injunction,
&c.:
To the Hon. Robert N. Martin, Judge of the Superior
Court of the City of Baltimore, sitting in Equity: The an-
swer of Lefevre Jarrett, Wm. H. B. Fusselbaugh and Jas.
E. Carr, constituting the Board of Police of the City of
Baltimore, to the bill of complaint and injunction of Alex-
ander M. Rogers, William Kennedy, John Clark, Johns
Hopkins and Benjamin Deford, filed in this court against
them and William Thomson, sheriff of Baltimore:
These respondents, reserving all proper exceptions, say
that they are not advised as to the place of residence of
the said complainant, Alexander M. Rogers, but they are
informed and believe that the complainants, Johns Hop-
kins, William Kennedy and John Clark, profess to reside
and claim their residence in Baltimore county, and have
done so ever since the taxation of the City of Baltimore
on personal property has been onerous and greatly in ex-
cess of that of the counties, although they do and during
all that time have done business in the City of Baltimore,
and have had and still have all the benefits of a residence
there, while avoiding its burdens. These respondents
therefore charge that said Hopkins, Kennedy and Clark
are not residents, nor is either of them a resident of said
city, and that their allegation to the contrary is false. The
respondents believe that Benjamin Deford, the other com-
plainant, resides in the City of Baltimore. Whether any
of said complainants, as they allege, pay taxes "to the fisc
of this State" these respondents do not know, except from
hearsay. They are quite sure that said complainants pay
no taxes they can avoid, and they, therefore, neither ad-
mit nor deny the allegation of the bill in that regard,
leaving the complainants to proof thereof.
These respondents know nothing of the alleged quali-
fications of said complainants, or any of them, to vote at
all State elections, nor do they know what oaths two or
14


 
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Proceedings and Debates of the 1867 Constitutional Convention
Volume 74, Volume 1, Debates 14   View pdf image (33K)
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