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1 In the Circuit Court of the United States. In Equity. Richmond Safety Gate Company vs. Samuel H. Ashbridge, et al. October Sessions, 1900, No. 44. Statement of Defendants' Reply to Plaintiff's Facts 1900

handle is hein.trials/acpt0001 and id is 1 raw text is: IN THE CIRCUIT COURT OF THE UNITED STATES. IN EQUITY. Richmond Safety Gate Company I October Sessions, 19oo. No. 44. Samuel H. Ashbridge et al. J STATEMENT OF DEFENDANTS' REPLY TO PLAINTIFF'S FACTS. As the defendants in their brief have not specifically replied to the facts alleged by the plaintiff, nor set up distinctly enumerated counter facts, the issues are not clear. The plaintiff therefore finds it necessary to here re-state the defendants' reply to its facts and the counter facts as alleged by them, in order that it may intelligently reply:- i. Page 3 of plaintiff's brief. This fact is not mentioned in defendants' brief, and is there- fore admitted. 2. Page 3 of plaintiff's brief. This fact is not mentioned in defendants' brief, and is there- fore admitted. 3. Page 3 of plaintiff's brief. This fact is not mentioned in defendants' brief, and is there- fore admitted. 4. Page 4 of plaintiff's brief. This fact is admitted (page 26 of defendants' brief), although defendants seek to throw doubt upon it by calling attention

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