xt70zp3vt865_285 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/mets.xml https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46.dao.xml unknown 14 Cubic Feet 31 boxes archival material 63m46 English University of Kentucky Copyright has not been assigned to the University of Kentucky.  Contact the Special Collections Research Center for information regarding rights and use of this collection. Harkins Family papers Mineral rights -- Kentucky -- Floyd County -- History. Law reports, digests, etc. -- Kentucky. Mining leases -- Kentucky -- Floyd County -- History. Practice of law -- Kentucky. Bankers -- Kentucky. Banks and banking -- Kentucky -- Prestonsburg. Coal trade -- Kentucky -- Floyd County -- History. Lawyers -- Kentucky. Patrick, A.T. v. Mead, G.W. et al text Patrick, A.T. v. Mead, G.W. et al 2016 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46/Box_26/Folder_9/7615.pdf 1921 1921 1921 section false xt70zp3vt865_285 xt70zp3vt865 413313143 1; LL“ 1.. 14;:; . :‘1.
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 receivecl ‘77 votes for mid nomination as Circa“; Judge :1

aforesaio, and 11119.45 the said 0. Bo Wheeler received 63 votes 2:3

fior $3.161 nomination aforesaid, which said certificate was if;

affixea to the stub book from which thoballoto had been 23%

, voted. and that thereafter said; ballots, stub book and 3%
. certificate were delivered to the office of the Clerk of the 7%

Floyd Counts; Court within the time and. in the manner prescribed ‘4

bylaw; that said ballot box, stub books- ami certificate were

g so delivered to the office of we Clerk of the 310% County
- Court (no the {it}: (mg; of August, 1921, and that sale}. stub . If
I book fias plooeo by me soic‘x Clerk oi? the 310776; County Court {1
" in the vault in his Said office; ”shat at different and divers g!
fiimes since the aforesaid stub book. and cartiffiooto was gig]
deposited in the office of “the Clerk of the Floyd County gig

Court time said. 0. B. Wheeler was examining the samo and ii;

‘ other stub books and certificates relative to 9:916. Republican
722.

primary election for the office of Circuit Juéigze aforesaiég 7

that the Board of Election Commissioners Within and for 15g

1 Floya County, Kentucky met at the Com-“t l~£ouse in Floyd J

~ County, Kentucky on Wednesoay, linguist 10th, 1921, for the a}!

r purpose of canvassing and tabulat ing: the said votes of the
. fwd
g, primary election as returned. certified ‘o:7 the réSpedtive
‘ officers holding solo election, soul that at solo time the Mob
books and certificates were removed from the vault in the i

7 office of the Clerk, oftho Floyd County Court to the off-“ice

‘ of the Judge of the Floga County Court. and. so remained
‘ l in said office of the Judge of Moo Floyd County Court. and
' in the custody of the Election Commissioners of Floyd
, County. Kentucky, for a period“ of about two hours or more,

g _ _ and that while said stub books and certificates were so in ' g '5

_ ‘ the office of the Judge of the" Floyd County Court the 3am ;

C~ 3- Wheeler. the opposing candidate to the plaintiff herein,
\ requested and obtainedgpogmfieloo from thessaid Board of; _g _ g

 Election Gommiesionere to insoect and examine said stubs
and certificates aforesaid. and after receiveing such
V consent of said Board of Election Commissioners of Floyd
County Kentucky proceeded to and did examine and inspect.mfl
take notes and memorando from the said certificates afore-
said, and that the time Said Ifiemoranda and notes from said
I certificate were so taken by the acid 09 B. Wheeler the
certificate attached to the stub book for soid.Mbuth of Hod
Precinct Ho. 14. Floyd County, Kentucky, showed that the
plaintiff, e. T. Patrick. had received at said precinct 77
votes and the said G. 3. Wheeler had received 63 votes.
' That thereafter said etub books and certificate were deposited
in the office of the Clerk of the Floyd County Court during the
Econ adjournment of said Board of Election CommissionerS. sad i 1'
upon said Board of Election Commissioners recuming their-work
about the hour of two P.M. said stub books and centificates
' ‘ I were then taken from the vault in the office of the Clerk of the "'
Floyd County Court to the office of the Sheriff of Floyd County ‘:
where said ballots and certificates were being canvassed and E
tabulated by the said Board of Election Commissioners; that , gg
‘ upon examination and canvass of the certificate attached to said gg
' .. stub book: for said flout}; of mud Precinct E0. 14 it was then. it
found by the said Board of Election Commissioners that the fig
. Said certificate showed that the Plaintiff, ”A. '1’. Patrick, if
had received 77 votes therein, and that the said O. B. Wheeler -i%§
. had received 83 votes therein. . . ' :3?
Plaintiff further says that the said certificate of l§yé
. the officers holding acid election as made out and returned ‘ E:
by them did not Show that the eaid C. B. Wheeler had received g;
, 83 votes. or other number of votes over or above or in excess ‘gg
, of 65 votes. and that the said certificate of said Election . (it
‘- Officers holding said election hoe been altered, changed and iii?
;- forged by some person or persons unknown to this plaintiff, ;.éfiég

 and. the figure 6 in the figures 65 was chamgied anti forged to I
a. figure 8 30 a3 1.0 make the same read. 85, and that the 5am ' ‘
' certificate attached ’50 said stub book as appeared to the
Bogart} of Eleetion Commissioners 02? mflloyd County. Kent; 11:31:57,
Was: not the certificate Of thé offieers 210161119; said election ,
and is not and We not the certificate Showing: the number or? I 1
~ votes recei‘o'efl "0:; said C. B. Wheeler at $5118. election, but '
that the same as to the number oz"? votewreceived‘ by the saifl '
‘ C. 3. Wheeler was altered, changea and forged.
. The ylaintifr.further says that heretofore on 1
‘ August 12th, 1921, he filed his certain suit in the Floya
, Circuit Court, wherein the officer's holding 53am alection and
the Board of Elation Commiseibuere of Floyd County. Kentucky.
were made defenaants, whidh said action is entitled A. T. V
.. Patrick. Plaintiff, against £1. J. May and othgrs, defenflants, .-
- and that on eaia date, August 12th, 1921, he ohtaimeé an _ ' v
’1 injunction from the Clerk of fine Floyd Circuit Court enjoining 3
‘ and restraining A. J. 11327. A. L. Allen and 1:. Home as
* ' Election Comissioners a1” Floyd 00112571337, Kemuclcy, from
certifying to the Searatary of State the votes received by >
the said A. T. Patrick and the said C. B. Wheeler until and ' .
, . after Such time as tha Electidfi Officerg holaing saifi election 7
' had reassembled anti racer-flirted the Votes cast at said Mouth ‘1 ii;
of Lina precinct E0. 14:, Floyd County, Kentuaky to said Board ,
of Election Gomissianers of Floyd County, Kentucky, and flat ;
Said order 0f injunction was eiocutefi :1an the said A. J. 3
May and A. L. Allen, Election Commise inner: aforesai d, on
Saturday morning, August lamb, 1921, about the hour of 8:00' %%
‘ AJK. A certified copy of the record in 8am action, and 1‘
of said order of injunction and the return thereon are
herewith filed, referred to and made a part hereof. #3
. . , ,. . .4 , . . 3

 ‘,Plafizrtiff further eggs that on said date, the 12th
stay of August, 1921. he filed his said. certain suit in the
I Floyd flauntyxflxxxk Circuit Court, which action,is entitled'
A. T. Patrick as Plaintiff against G. W. Meade and others,
aefenaante, wherein he oought é mandatory injunction ggainst
‘ the officers holéiflg eaifl eleotion to compel them to reassemble
am to open the ballot boxes wiéea. in said Republican Primary
Election of said Mont? of Mué.precinet No; 14, and to recertify
- to the Board of Election Commissioners of Floya County.
Kentucky, the vote in said race for the office of Circuit ”
Juago of the Slat Judicial Bistriot of Kentucky, as between
0 the soia 3. T. Patrick and the said 0. B. Wheeler. anfl that
in saia action on the Eith day of August, 1921. a.mondatory &
injunction was granted by the Honorable William O. Kalbert, f
' ‘ Judge 20th Judicial District of Kentucky, a certified copy of
' which record is filed herewith and as a part hereof.
Plaintiff further says that notwithstonfling saia
I injunction thich was executed upon,the saifl A. J. may anfi A. L.
’ I Ellen, Election Commissioners aforesaid, on August ESth, 1921, ,
they each unlawfully. illegally and'without right, and in .
~ violation of saifi injunction one in contempt thereof, on ‘
August 15th, 1921, certificated to the Clerk of the i‘loyfl
0 County Coort the votes receivoo in said Primary Election in
' Floyd County, Kentucky, as: to the gait} o. B. Wheeler and the
1' said A. T. Patrick, and certifieé that in said mouth of Ema 0
I pfeoinot E0. 14 the said A. T. Patrick receive& 7? votes anfi ’ “
" the said C. B. Wheeler received 85 votes, and that immediately
V thereafter the said Mark of the Floyd County Court certified V
'3: the votes cast in said election as to the said 0. B. Wheeler
and t. T. Patrick to the Secretary of State of Kentucky. ' y
: Plaintiff further says that on the 15th,day,of f
‘ August, 1921. the injunction granted by the Sam mum: c. 1
' Halbert as hereinbefore set out, was executed upon.the ,0
‘_ officers holaing Said election in said Mouth of Mud

 gracinct Ho. 14 aforesaid. and that in pursuance to said ”
injunction said clection officers aforesaid reassembled at
the office of fihc Clerk of the Floyc County Court on the
17th flay of August, 1921, and cftcr opening the ballot l'
boxes used in ccia.£epuhlicao Primary at said Election that
‘ said WW Board ..’-5 Ele cticn Officers rcccr‘tified
scifl-vote anfl certified that the ccid A. T. Patrick receivcfl T
?7 votes in Said precinct, cnfl that fihe scia C. B. thclcr
‘ receive@ 63 votes in saia precinct; that the certificate cttcchcfl
.V to the Stub book ucec in caic.prccinct was changed anc corrected ’T
l! by ecia officcrc holding said election so as to choc that .
T che ccic 6. B. Wheeler receivea 63 vctec in caid precinct
I: instecc of 83 vohes, ago that the said election officers
5 further affixed to ecic.stcb Book an amended, corrected cnc .
Q substituted certificate ccrtifying that the said C. B. Wheeler _
'L» reccivcc 63 vctcc ac scia precinct and the said A. T. Patrick
T1 77 votes in said precinct. A copy of the amended, corrected :
.i and substituted certificate of said Boara of Election officers t
T. is hereto attached and mace pcrt hereof. ‘5
'7 ‘ That thereafter and on the 17th day of August, ..
1921, the $2.16 A L. Allen and ..:»... J.. May, being “awe of the ,
1;, members of the Floyd County Bocrc of Election Commissioners, ‘
yd ‘ reassembled pursuant to said injunction of the said William T
c. Halbcr’u, Judge aforcczhid, aim rccertificd “the number of
TTT votes cast in said Primary Election as to the acid A. T. .
T: Patrick and C. 3. Wheeler to the Clerk of the Floyd County j
m; Court in the manner prescribed by law. A certified copy
I”) of said amended certificate is herewith filed and.made part
3j hereof. T I.
‘ Plaintiff further says that the eaié certificate
g made by the Bocra of Election Commissioners of Floyd Gonnty,
l; Kcntccky, adb certified and transmitted by the Clerk of the 53;
6 it

 I Floyd County Court to the Secretary of State on Monday,
‘ August 15th, 1921, was in disobedience of the injunction _
I ‘ hereinbefore 96% out, and by reaeon thereof was and is -
null and void. - ‘ I
Plainfiiff says that %ho defenfiants herein, compoéing o
,‘ the State Board of Election Commissioners. are now in Session
‘ at the Capitol at Frankfort, Kenfiacky, and.that he is informed,
1 ' believes. and upon ouch information anfi.belief alleges that the
; Said defendants, oompdking the State Boarfi of Ekaction Coma ‘
‘" ' miesionoro aforesaid, will diskegarfl said.amen&ed. correcfied ‘ '
1‘ ana substituted return and certification from the Board of 1
,' Election Commigeioners of Flojfi County, bearinr date August
7“ IVth, 1921, an& that giaé¥gu§§§gifi amenaefi, corrected and ”
'fiv sdbotituted certifieafie of the Board of Election Commissioners
:7 of Floyd County, Kentucky, is digregarded by the defendants ‘
‘ compsosing fihe State Boara of_Eleotion Commissioners fihe ”
:1 reeu1t will be thafi the sai&.Boara of Election Commissioners
V,: of the State of Kentucky will EWard the certificate of ‘
1 nomination to the oaifi C. B. Wheeler instead of to this
‘= plaintiff, and that this plainhiff received the majority
'{7 of the leggl votes cast at gala Primary Election and is v
7; entitled to the certificate of nomination as the Republican .
‘.“. candidate for the office of Circuit Judge of the slat Judicial 1‘
4' District of Kentucky, and thaf shoula said certificate of
‘3 nomination be awaraed by saia defendants composing the 1/ ‘
1; state Baard of Election Commissioners to the said 0. B.
: V ‘ Wheeler this plaintiff will be involved in contests of said
'" election and numerous and vexatious suite at law and of “
‘ contests. ,
Ni Plaintiff further says that by reason thereof he i
is Without adequate remedy at law. j
W? Plaintiff further $335 that great and irrqparable ‘ "g
«<’ injury will result to him from delay in giving notes of i;

 I. . 2 ‘ ‘ v ' ~ ' . >. I ‘ L‘l: V ‘ ’ . . ‘ .
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Team. of 3:233 G‘s ion Comaisaiomarg 01" 73193-8. Cmm’cy, Kentucky, '
' and 05‘ 53h?) Beam of 13162.25. 5:311 Comaieeioners 01’ 13210131; (Sammy,
Kentucky, and for 23.1 general and special relief.
_ A. T. szamze: '
By Atty.

 STJH’E 0F QEECEN TUCKY , V
/ / ::ct . 1 , .
‘ Flt—1131:1311! COUXWY "
The affiant, A. ‘1‘. Patrick, says-s the statements V
‘ continues: in. the 22330er am}. f6?f€:§§0112§f‘p8‘5311110fl are firue as
I he helieves. ‘
‘ Subseribeé and sworn to before me 13;; A. '1’. Fatrick. '
' fishis the ___ day of gmngt, 1921.
a 351mm; ?ubiic, E'rgzmlin 50. , "j
Xe Mucky“ .'.

 ‘ 3'3me CIRCUIT comm ‘
A.*T.PATZ~EICK,......a.s........PLAIHTI}FF, '
v.23 /// E’E’i’lii’lflfl mmmm.
ROY SPEOK, ' I '
V WILLIAM ELLYBIEEPE and .
  ‘Jc. B inkova, . a . a . . a a a . ., . , . . , DEFENDAMS.
The Elaintiff, 3. T, Patrick, says that be is a ‘
‘. citizen'and résiéent of Preetofishurgw Flcyé Counfiy, Zhntucky, ,
find of the Elst Judicial Distifiet of KQDtucky. - I
  That the Defenfimi‘iss, Roy Speck, William Rayburn 2:161 __
J. H..?olsgwove are the auly elected, appointea, qualified '  
I. an& acting Boaré of Election Cbmmissioners of and for the
: State of Kentucky. '
  fi‘hat at the Primary Election held; on August 6th, '
1921, the names of the Plaintifffi A. T. Patrick and C. B. '-
Wheelar were each auly and legally placed upon the ballots ‘
5 to he voted for as canaidates for the Republizan nominaxion J-
V for the office of Circuit Judge within an& for the Slat
Judicial Diefirict of Kentucky; that Said Elst Judicial ‘ 7-
’ ‘ District of Kaptucky consists of the counties of Floyd ana
. Rhett. ' ‘
‘ , ’That after the closé of said election, and after V'
‘L ' the count was made of the ballbts and votes cast in Said
' primary election in the Mouth of Mud-Precinct No. 14, I
Flcyfl County, Khutucky. Said officers who held an& conducted ’7;
said election, made a certificate of the votes cast at said u;
~ election and certified that the plaintiff, A. T. Patrick %;

 I mom 6136111: scum: -
. L A. T. PATRICK,,,,,... ,,.....,,,. PLAINTIFFAND "
‘. CONTESTAMD.
vs /// NOTICE AND GROUNDS or CONTEST. '
w.‘ w. WILLIAMS and -
JOHN M. BAKER, . ,‘, . , , . . , . , , , , . , DEFENDANT and
_ CONTESTEE.
T0 w. w. WILLIAMS AND JOHN M. BAKER: ‘
Notice is hereby given that the Plaintiff and
Contestant, A. Ti Patrick, intends to contest and does hereby
contest the nominat.on of W. W. Williams as the Democratic
Nominee for the office of Circuit Judge of the 31st Judicial
. District of Kentucky. and does further contest the votes ,
a. received by the defendant and contestee John M. Baker as candidate for the Democratic nomination for the office of
' Circuit Judge of the 3lst Judicial District of Kentucky. and
you and each of you are warned that you and each of you are
, required to answer and defend such contest at the office of V
' the Clerk of Floyd Circuit Court on the 2nd day of September,
1921. at 9:00 ggiclock A.M.
~ ' The Dlaintiff and contestand says that heretofore :
’ the names of the Plaintiff and the defendants, W. W. Williams E
”_ and John M.‘§aker were duly and legally placed upon the ;
ballots to he voted for at the Primary Election held in and i
, for the 31st Judicial District or Kentucky/on the 6th day of I
‘ August, 1921. as candidates for the Democratic nomination for ‘ é
» the office of Circuit Judge of the 31st Judicial District of {
Kentucky. That said 31st Judicial District of Kentucky E
. consists of the counties of Floyd and Knott. That after said L
election was held the officers holding said election made a

 count and tabulation of the votes so cast in said Primary .
' for said Democratic nomination for the office of Circuit
. Judge of the 31st Judicial District of Kentucky to the Board '
. of Election Commissioners of their respective countiesof
Floyd and Knott; that thereafter the Board of Election
Commissioners within and for Knott County, Kentucky, met f
and tabulated the votes cast for and on behalf of the E
/ “7 Plaintiff and the defendants herein, and certified same to .
VW/ the State Board of Election Commissioners that,the said W. W..
/t/ Williams receiver 1191 votes; that the said John M. Baker l
[.54 received 1577 votes, and the said A. T. Patrick received '
‘H I 00 votes in said Knott County, Kentucky; that the Board of
Election Commissioners within and for Floyd County, Aentucky,
/ ‘ within the time perscribed by law met and tabulated-and canvassed
a. the votes cast in the divers precincts of Floyd . ,
I? . County, Aentucky. and have certified to the State Board of . f
9 Election Commissioners that the said W. W. Williams received .
- 3121 votes; that the said' John M. Baker received 1255 votes,
V and that the said A. T. Patrick received 123 votes as =
candidates for the Democratic nomination for the office of
' Circuit Judge of the 31st Judicial District of Kentucky. and ‘
hf Floyd County. . , 1 . ' ='
That heretofore and on Saturday August 20. 192d. 5
the State Board of Election Commissioners within and for '
‘ the State of Kentucky met at Frankfort, Kentucky and -- '.
tabulated and canvassed the votes so certified before them,
, and that as a result of such tabulation and canvass the ** E
State Board of Election Commissioners determined that the said,

‘ W. W. Williams received 4312 votes; that the said John M. Baker ‘
received 2772 votes, and that the said A. T. Patrick had _ -
received 123 votes as candidates for the Democratic nomination
for the office of Circuit Judge of the 31st Judicial District

 of Kentucky. and that by reason thereof certificate of ‘
nomination should be issued to the defendant and contestee,
W. W. Williams.
As grounds of contest herein of said nomination
of the said W. W. Williams aforesaid and of the votes cast
for and on behalf of the said John M. Baker, the plaintiff
says that different and divers corporations. persons. companies
and associations, whose names are at this time urknown to f
, plaintiff and contestant. unlawfully and illegally contributed :
' money toward the nomiration of the said W. W. Williams. and I "i
/ toward the attempted nomination of John E. Baker as candidate
. for said Democratic nomination of Circuit Judge aforesaid.
That the circuit Judge of the 3lst Judicial District of
I - Kentucky in his official capacity is required by law to . _
;‘ ‘ perform duties peculiar to such corporations, persons. 5
l ‘ companies and associations not cnmmon to the general public,
” and that it is the duty of such Circuit Judge aforesaid to
' , .supervise. regulate or control the affairs of such corporations, ’
companies, persons or associations in so.far as there may be I
action pending either in the Floyd Circuit Court on the Knott ‘
’ Circuit Bourt of the State of Kentucky peculiar to such v
corporations. persons. companies or associations and not a
‘ common to the general public. That said corporations. ‘
associations. persons and companies by and through their 3
- officers, agents and servants on behalf of such corporations,
companies and associations have paid, promised and loaned. or
, otherwise become perurnary liable for money andother things /
V .of value in behalf of the said W. W} Williams and the said '
m John M. Baker as candidates for said Democratic_nomination A
“ for the office of Circuit Judge aforesaid. ,
i . , -3- a ,

 L _ II ' '
That the said W. w. Williams and John M. Baker ’
and each of them have unlawfullyyillegally and without
right expended money and other things of value, paid money and "
‘ other things of calue, promised money and other things of
value, loaned money and other things of value and become
pecuniary liable directly and indirectly to different and divers
voters Within and for Floyd County, Kentucky, and within and for
Knott Caunty, Kentucky. in consideration of which said persons
' and voters agreed to vote for and support and did vote for and
' support the said W. W. Williams and the said John M. Baker and A
each and both of them, and that the ballots of each of said I
voters were placed in the ballot box, and were counted for the
. said Williams and Baker. respectively.
III
I The Plaintiff further says that the said defendants. ,
. « W. W. Williams and JobIlE. Baker each unlawfully. illegally
, aha corruptly expended and caused.to be expended each for his- (
self in said Primary Election sums of money in excess of
$2500.00, and that said expenditures were made by the said‘ ‘ '1
W.W. Williams and John M. Baker, each by himself and ' V
by others working for and on behalf of the said W. W. Williams ‘
and JOHN M. Baker. and with the knowledge and consent :1 and
I - Iapproval of the said W. W. Williams and Joher. Baker each as
to the amount of money unlawfully. illegally or corruptly /
-expended for and on behalf of themselves respectively. That
, $2500.00 was the greatest amount which the said defendant,
W. W. Williams could expend or have xxpxxdxd spent for him at or
_ before the Democratic Primary, and that the said sum w as the
~greatest amount which the said John M. Baker could legally -
expend or have expended for and on his behalf as aforesaid I ~
candidate for said Democratic Primary aforesaid. ‘ 0
~ -4- w

 IV
Said Plaintiff further says that the said defendants,
W. ‘31. Williams and John M. Baker each unlawfully, illegally and
' without right and corruptly caused different and divers voters
to be bribed to vote for and did vote for and on behalf of the
, said W. W. Williams and JOhn Iv]. Baker respectively, and that said
bribery of the voters was done by and, with the knowledge and
consent of the said W. W. Williams and John M. Baker respectively '
V as to the respective votes bribed for and on behalf of the said
W. W. Williams and for and on behalf of the said John M. Baker.
Contestant further says that in said Floyd County,
Kentucky, there were and are 28 vet-ing precincts, and in said
Khott County, Kentucky, there were and are ___ voting precincts,
r and that in each and. every of said precincts in said ~F'loyd
' County, Kentucky,«and in said Knott Cpunty, Kentucky, said
’ defendants, W. W. Williams and John M. Baker each for himself
- unlawfully, illegally and corruptly had Irepresentatives ‘
present thereat who were plum provided with money for the
‘ unlawful, illegal and corrupt purpose of'bribing voters to vote
f for them and each of them respectively for said nomination
aforesaid, and that the said representatives and agents of the ‘
i said W. W. Williams and John M. Baker aforesaid each unlawfully, ‘
illegally and without right, and with: the consent and approval - '
of the said. w. w. Williams and John it. Baker unlawfully,
illegally and without right and corruptly bribed divers voters
1 within and for said voting nrecincts and each of them respectively
' to vote for and did vote for andvon behalf of_the said John M. A
. .. I “Baker and W. W. Williams respectively. 1
> ‘ Contestant says that the said‘defendants and each ,
of them have unlawfully, illegally and without right and ‘
x \ corruptly violated the laws of the State of Kentucky known as
I the Corrupt Practfin'é: Act, and that by reason thereof the
-5- ' ’ '

 nomination of the said “. w. Williams to said office as
said Democratic candidate aforesaid was and is null and void.
4” and all votes cast for and on behalf of the said W. W. Williams
by reason thereof were and are null and void and should be
excluded and not counted for him.
_ That the votes cast for the said John M. Baker by
1 reason thereof were and are null and void and should.be L
1 excluded and not counted or considered for the said John E. .1 1
Baker. I” 1.
. Plaintiff further says that he has fully ccmplied g”
with all provisions and requirements of said Act of the {1
Kentucky Legislature and law of the State of Kentucky known 1
as the Corrupt Practice Act to this time that he did not expend .
or cause to be expended or permit to be expended or have expended
with his knowledge, consent or approval any money or other things \
‘ of value whereby any voters could be influenced or bribed to bots
for or on behalf of this Plaintiff. or other money or things .
. of value, or other purpose than such as legally to be expended
'and that the total amount of his expenditures as such
candidate for said Democratic nomination was and is
1 less than the sum of $2500.00. 1 '
The Plaintiff further says that by reason of the .
violation on the provisions of said Corrupt Practice Acton the '
. part of the said W. W. Williams and the said JOhn M. Baker - ‘1
‘