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1 In Chancery of New Jersey. Between the State of New Jersey, by Jacob Vanatta, Attorney General, Relator, and The Hudson River Chemical and Dyewood Company, Defendants. Brief and Points for Defendants 1800s

handle is hein.trials/aaoa0001 and id is 1 raw text is: .ei Between THE STATE OF NEW JERSEY, by JACOB VANATTA, Attorney General, Relator, and THE HujDSON RIVER CHEMICAL AND DYEWOOD COMPANY, Defendants. Brief and Points for Defend- ants. That the imnprovements, complained of, which consist of the filling in, the building upon, and the making erections on and reclaiming land under the tide-water of this State, referred to in paragraph 4 of the Infor- mation, with the exceptior of the triaiqplar piece in front of the Kemp tract, and adjoining the north line of the Finch tract, were all done in front of the Finch tract, and within the liNts q/' the Freehldrlos License. The Relator, by the testimony of witness Payne, page 39, line 11, page 40, line 1, and by Exhibit R. 3, attempts to show the /mcatio, of the Freeholders License to Finch. By this evidence the greater part Q/' the location is in ,'ront q the lands ./brmeily ?/' Kingsland & Sutton, now Page, Keter awl Fletcher, which lands are south of the Finch tract.

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