25 10 9760 https://caspercollege.cvlcollections.org/files/original/aa8fb1b54e4424cbd8241a3b3d81dfc4.pdf 4f82b2739bd8e968b63aa8c714924031 PDF Text Text THIS Made and entered into this 16th day of May, 19Z9, by between the Conningh&a Sheep Company of f^dletCHs^ Oregon^ here* inafter known as the party of tbs first part, and Boy B« Moore, of Birsa* ston, Wyoming, hereinafter kno'm as the party of the second part, and l^y B. Minty of Cas^r, l^cnsing, herelnisftcr knoMi as the party of the third part, "Hiat tiw party of the first part has an agreeaent with the party of the seeond part i&erehy We par^ of the seeond part represents first oftrty in the sale of bucks in the State of Wyoriing. ISD said agre^ent penalts second party to select and appoint such sub-agents as is agreed advisable by first and seccajd parties* ^11 Wi£££&B We second pahr^ is" desirous of naalng third par^ sub-agamt to handle bucks in Wyoming wader his supervisicm* SHBHOOBB it is agreed between the parties hereto that the party of the first part is agreeable to the appoInta eat of third party as sub* to sell ^xnnlnghaai bucks la the following described Wyoalng terri* toryi 111 territory tributary to Casper on the South, and Bast to Chug­ eater and Bast of Chugeater to the Mebrasiea llne| Sorth along the Mebreska line and lest to Moorcroft, Gillette, and Buffaloj thence west of Buffalo to the Big Hora Mountain Divide; such territory to include all conwalties adjacent to Buffalo, Billette and Moorcroft; thenee Booth frcm the Big Hom Mountain Divide and aixmg such divide thru Brain to and <m South to the vleiaity of IndepeoMkrnee Boek, Wttoee Sasteard ta the place of beginning* Bucks eonslpied by first party to the looming Bm Bale are excluded frcm the terns of this agre^sent but such eonsiganent shall not exceed one boadred head* Zt is hereby agreed and understood that We party of the third part is to work under We direct supervision of second par^ and that he Is to consult with second par^ ccmcemlng ecmditlons surrounding We sale of said bucks; that third parly shall be paid a commission of 10% ou the gross sale of said bucks, that all payments for sales made are to be forwarded to sectaid party at Evanston, l^oalng. Checks, drafts and all other evidences of payn«»t to be aade psyitble to We Cu^lnghea Sheep Company sad second p&r^ agrees receipt of said payment to pay Wlrd party cm behalf of first party ail conaissloas due whm collections are made on checks or drafts* ^Ird party agrees to send a stBtiwffiut of bucks sold together wlW the names and addresses of parties to whem sold to seeoM party, with re- siittances for .. It Is further wo^erstocKi and Wat third party agrees to handle no other Rambouillet or Crossbred Dlacoln Baabouiilet bucks except those of Cunnlnghe* breeding during We period of this agreeaent unless specific arraageaent with first party* It is agreed and understood Wat first party will make every effort to select and send to third party first class bucks and that third party will recetve said bucks, taking care to locate Wens on desirable range and that Wlrd party will sake such inspection of said bucks during We uonWs of June, July add August as to be assured Wat they will be In aarketeble condition on or before September 1st* �. Patee Third party agrees to consult with sepoac party as to locating said bucks for su®a©r pasture and as ■to prices to be asked for the same, and such other matters as may ba important in the handling of ssiid bucks. First par^ agrees to pay all expen-ses> feed and care, for such bucks as aay be shipped to the third party and third party is hereby authorized to draw against first party for such charges, if such charges are approved by first or second party. IMrd p&rtsr agrees to furnish second party invoices and statements of charges* it Is hereby agreed and understood that title to bucks shipped to third party for sale shall rmsia in the party of the first part until fuUy paid for. It is further understood between the parties hereto that this agree* aent may be cancelled as to ary future year by any of the three contract­ ing parties by giving written notice to the other parties on or before the first day of January of such year. -• . WilSiSSS OOR SASSB this____ Jey of Bay, 1959. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Cunningham Sheep Ranch Contract Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1939-05-16 Type The nature or genre of the resource Text Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_CunninghamSheepCompanyContract Format The file format, physical medium, or dimensions of the resource PDF Extent The size or duration of the resource. 2 pages Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/546aaea73dfb6a32be7efac718bd966a.pdf e88f960f7903e1bc785b240c88e50d47 PDF Text Text THIS y!E?.!ORAIWUT.- OF AH AG-REE^ffiNT, Made and entered into this December 1, 1937, hy and between Adelaide Smith and Oeoree E. Smith, wife and husband, of Johnson County, V^yoming, first parties, and Roy B. Minty, of Casner, Wyoming, second party, WITNESSETH: That for and in consideration of $1.00 and other good and valuable considerations paid to the first parties by the second party, receipt is hereby confessed and acknowledged , the said first parties do hereby give and grant unto the second party an exclusive option to purchase the following described lands and premises, situate, lying and being in Johnson County, ^’■oming, to-wit: TOWNSHIP 47 North of Range 80 West 6th P.M, SW-JnE:|’, NWjSEi-, Lots 2, 3, 4 Section 30 TOWNSHIP 47 North of Range 81 Vfest 6th F.M, Il Lot 4, SW^Tff| Section Lots 1, 2, St^NB^, SSJ E--E.V NEi, WJ:<, NEiSWi, N^-SEi 2 3 10 11 12 13 14 ' 15 25 L. a'W.t*,'' w| W-^NWi, SWj, N-^-SEi e-^neJ, S^ NBJseI, i^ssi TOWNSHIP 48 North of Range 81 West 6th P.M, SE^SEJ W^SW^ Section 34 35 Containing 2643 acres. The second party is hereby given en option for a period of -06^ days from and after December 1, 1937 to purchase ths said land and premises for the orice and upon the terms and conditions following, to-wit:- The consideration to be paid for said lands is the sum of $9.50 of, 135,108^50, The sum of one-r^.lf the araount in excess of the loan from the doming Farm Loan Board on said described property shall be paid in cahh at the time option is exercised; the balance shall be due and uayable 6 months from date of initial uayment with interest at the rate of seven percent ner annum, the second oarty to secure the payment of said balance to the satisfaction of the first parties. �It is expressly understood- and agreed that the first parties reserve one-half of all mineral ri^ts, particularly oil, in said lands. This agreement shall he binding upon and inure to the heirs and nominees of the second parties. IN WITISSS TOSISOJ thia agreement has been ez^cuted. in duplicate the day and year first above written. �/k-cf o '^ C-C-<^^'^ If 'Ji /L. C2.cZ^<--<^ <^i<...-<^[ (0,.^^,,,t_^«_X a^ J /i^ A ' ' C �Mr. Qeorge E« Smith B^yffalo, Wyoming Dear Oeorge:* Please find herewith form of option to oover your ranch land which you will probably find satisfactory. You’ll notice on page one I have left ample room for you to run in the legal description of your land* I have also Inserted the price at $9«50 per acre straight across, regardless of the number of acres you liave. In addition to this option, I require a letter fully describing your ranch, giving all information with reference to V’ator-righta, the status of your State loan, and any such i'urthsr information as will be of interest to my pr ospective buyer. There has been so much uncertainty in the pastwithreference to the sale of your ranch, and I hove, at different times, been put on the spot with my prospective purchaser because I was unable to make any definite statement. For this reason, I consider an option legally executed very necessary before I proceed further wltli tills deal. I must be in a position, if I resume negotiations, to state definitely just wiiat X can do and tills will not be possible unless I have tlie option properly executed. If the option contains any agi*eem6nt not satisfactory to you, please advise, or make such changes* sign it, and send It to mo for my signature; and if I find such change agreeable, I will iimaedlately attach my slgnatta?e and return original copy to you. Best regards, X am Yours very truly, EBM/h ROY Q* UIMTY �! f "I �1206-A CLASS OF SERVICE DESIRED’ transmitted as a full-rate commgni cation. WESTERN UNION R. B. WHITS paaaiDCNT NEWCOMB CARLTON CHAIRMAN OF THS BOARD J. C. WILLCVER FIRST VICS-PRBSIOeNT Send ihefolloieingmeiaage, aubjeclfo the terms on back hereof, which are hereby agreed to WESTERN UNION GIFT ORDERS ARE APPROPRIATE GIFTS FOR ALL OCCASIONS CHECK ACCT’G INFMN. TIME FILED �Sept. 20th, 1937 Mr. R. B. Minty, Henning Hotel, Casper, Wyo Dear fioy:- With further reference to our ’phone conversation concerning the 2860 acre ranch of Geo. E. Smith located about 22 miles South of Buffalo. As near as I .am able to make out, there is at present an indebtedness of about ^16,830.73 against this property which loan is carried by the State of Wyoming. I believe that the loan originally was about $14,000 and the present loan now con­ sists of the following: Amount of balance due on principal Four delinquent payments of $970 ea. 1937 installment Total - $11,980.73 3,880.00 970.00 $16,830.73 As you know, the original Smith Bros, ranch was split up two years ago and George took the upper part of the ranch and young Robert took the lower part of the ranch. It is a good ranch and carries an excellent water right. In fact, they have plenty of water for their irrigated land. Mrs. Al Smith now desires to purchase the Geo. Smith ranch if it can be accomplished and she proposes to put Alfred L. Smith on said ranch so that each of the boys will have a good set up. I do not think that George really has any bonafide prospect to purchase his ranch and I suggested to Mrs. Smith that she go back to Buffalo and offer George $20,000 for the ranch. I figure the ranch worth $21,080 based upon the following values: 320 A, irrigated land & $50,00 per Acre $16,000.00 2540 A. of Grazing ” O $2.00 per acre 5,080.00 Total. "$21,080.00 �However, Mrs. Smith would be willing to pay a little more than this amount for the ranch as it really goes in connection with the land that is now owned by her son Robert C. Smith. I doubt very much if the State of Wyoming will be willing to carry on their loan in its present condition for an indefinite period but Mrs. Al Smith advises me that George will have sufficient income this year from the crop to make the 1937 installment payment of $970.00. For this reason if he makes this payment and pays the taxes I would anticipate that the State of V/yoming would carry on for another year rather than foreclose. I told Mrs. Smith that I thot you were the one to handle the transaction for the reason that there is considerable jealousy between the family of George Smith end Al. Smith and I doubt very much if George would sell to Mrs. Al. Smith or to either of her boys. Apparently they get along Ckeh but George feels that he has received the worst end of the deal in the split up of Smith Bros, at the time of the death of Al. Smith. In view of these circumstances, you will now know that Mrs. Smith is making a direct offer to George to purchase his ranch for the sum of 120,000 and this will give you a basis to work on. With kind personal regards, I am, Sincerely yours. V/. E. Fair WEF:0E. Vice President. ��September Sd* 1957 Ur* Qeorge E. Szaith Buffalo, WyOTiljfjg Dear Oeor^i - I fflsi Just In receipt of a letter from B proapectlv© ranch buyer In which lie ad­ vises he has recovered from a recent lllneaa and In the next day or two will be Interested In the ranch In Johnson county* If you have done nothing up to date, please advise and lets get going* n© apparently believed what I told him about this ranch and the country and Is anxious to see It before he looks at anything else* With best regards, X aza Yours very truly. RBK/h ROY 3* unm �.^'■^a-.t,^^ (S-ec.,^ yiLi^ <i.-<,x^> £4-- - d?c-^^ ��Buffalo, Wyoming December 1, 1937 Mr, Itoy E. Minty Casper, looming , A> . " * ' * t . *-~* ** . Dear Roy: I receive:’, th? copies of the ontion and for the most nart they v/cre satisfactory. Inasrmich as there were several changes how­ ever, I thou^t it advisable to have them recopied. In the first nine© the title to the ranch is held in ray wife’s name, Adelaide Smith, so I added her name to the option. In talking with the representative from the Ferra Loan Board I found that they ob­ jected to a 120 day option since it runs too far into the spring and might prevent me making other arrangements if this deal did not materialize. I believe you can appreciate the situation in this regard. For this reason I have specified 3C days, but if there would be any reasonable prospect of closing a deal we could grant you at least another 30 days. In view of the comparatively low price of $9.50 an acre we thought that a half of the mineral rights should be reserved. I trust that this will not be objectional. Since the second payment is to be made 6 months in the future I thou^t we should heve some security for this but no doubt this detail can be satis factorily worked out when the time comes. I thought you might wish to show ray other letter to a prospective purchaser so I did not include the above matters in it. I trust that everything is satisfactory, but if net kindly advise rae immediately. With personal regards. �Buffalo, Wyoming December 1, 1937 Mr. Roy B. Minty Casper, doming Dear Mr. Minty; I am enclosing an option to purchase our ranch on Cra^y Woman Creek v^hich has been executed by both Mrs. Smith and me and I trust it will be satis­ factory. In accordance with your recent letter I shall endeavor to give you all the information I can in regai'd to the price. As stated in the option there are 2643 acres in the place, over 400 of which are irrigated, and the balance is grazing land. Practically all of the irrigated land is level or very gently rolling, and the grazing land is exceptionally fine. The soil on the place for the most uart is a sandy loam and produces excellent crops. Crazy Woman runs through the entire length of ths ranch so there is ample water. There is a water right for 406 acres which bears Priority No. 2 in Crazy Woman. The only ditch ahead of it is a small one from Billy Creek which is a tributary of Crazy Woman, so for all practical p-nrposes we have a No. 1 priority. I might mention that this water right ’.vas adjudicated by a Court Decree on July 5, 1839 end is considered by many authorities superior to the ri^ts la^^^icated by the State Board of Control. We have a. half interest in” the John S. Smith Ditch, the balance being held by Robert Smith, my nephew, who is the owner of the remainder of what was originally the John R. Smith Ranch. Por your further information I ora en­ closing plats showing the water on each 40 acres of our land which I have secured from the State Engineer’s office. Never since we have had the ranch has there been a shortage of irrigation wp.ter. In connection with the water situation I might add that there are 3 reservoirs located on the grazing land, two of these having been completed under the Government pro­ gram, and all of which give an abundant supply of stock water. There is a mortgage to the Wyoming Farm Loan Board on which there is a balance due on the principal of approximately $11,600 which the State will undoubtedly be pleased to carry under its present terms. In regard to the inp^rovements there is a three room house, a bunk house, a bam for eight horses, a shed, cellar, chicken house, corrals and ice house. The north and west sides of the place are fenced with three barb �wires with woven wire beneath. Also there is a 60 acre hog nast-are fenced entirely with woven wire and some cross fencing of the Rane type The balance of the outside fence is made of three harh wires with nitch or cedar oosts which are not over two rods apart. Although I did not include it in ths option, ny sister, Wyoming E. Smith, owns the S^4 Section 2-47-81 (160 acres) and this can he purcliased on the same terms and included with the proposed transaction. Nineteen acres of this is irrigated. you the information you desire, I am, Very truly yours, Gsorre Z. 3:.uth �Buffal 0 > Wyoming December 41937 Mr. Roy B.Minty Casper, Wyoming Dear Boys 1 received your letter and the copies of the Option which you returned. Altho the 60 days is really longer than I thought I should give under the circumstances I have changed the time to 60 days iriiich will give you until the end of January. I have just changed the time specified in the contract and I am returning the original to you. I am glad to learn that your purchaaer is still interested and with best wishes, I am Very sincer-^1 Geo. E.Smith �Deodobop 6, 1937 Mr, C. H, Mc’Milnnle ComiBslonop of Public Lands Cheyenne* Wyoming^c Door Mr* UeWiilnnlos^ X aa anxious to aeouro information with reforenoe to a loan your ooiaaiasion has made to Adelaide i^mith and George K, Smith* husband and wife, of Bx^ffalo, ^i:,0Ei5,nQ, nils Itmd Ib cltuated on Ci»b.ay Woxoan in Township 47’ K,* Range 80 v <* find in Twp« 4i^ Kan^.e 81 V*eBt. Kot 1 rtiiig fard.lirr witli the policy of yoiu' office* I am not sux-e thiit thle irfonnfition will he available* wnd certainly would not ank you foi- it if It wei-e not of vital intoroot* X an at tliie time negotiating and* ae a liiatter of fact, hove option (to buy) on thle land and, of eourae* it la of Interest to know the exact status of the State lead* I will appreclpte very much If this infox*mation la available and can bo foirwarded to aae Thahking you in advance* X am Very truly yours* RBSVh ROy B. MIHOT �^tate of OTpommg OFFICE OF FARM LOAN COMMISSIONER CHEYENNE C. H. McWHINNIE ALBERT P. BRUCH COMMISSIONER ASSISTANT COMMISSIONER December 8, 1937 BERNICE C. QILL DEFUTY COMMISSIONER Mr. Roy B. Minty General Commission Casper, Wyoming Dear Mr* Minty Re: Loan N0.13IO-J. - Adelaide Smith We are in receipt of your letter of December 6 and we are pleased to inform you that on April 15> 1937> five Instalments of §910*73 had matured* We also carry an advance of $3»5O» Therefore, the total delinquency as of that date Is $U557«15* When this has been cleared, the unpaid balance will be reduced to $11,006.21. Should you care to figure the Interest to date, kindly add thereto 5% Interest on the unpaid balance. You will note this loan Is In a very serious condition and this Department feels some very definite arrangement will need to be accomplished for early reinstatement otherwise the matter will of necessity be presented to the Board with a view to foreclosure* We trust this gives you the information desired* truly ssistanv Qonmlssloner APB:MM ��ROY B. MINTY Casper, Wyoming COPY December 10, 1937. Mr. William E. Fair Sheridan, Wyoming Dear Bill: - Since our phone conversation with reference to the Staith deal, I have succeeded in securing from George and Adelade Smith an option‘on the property in question. This option is given for a period of sixty days from December first. The property consists of 2,643 acres and the optional price is $9.50 per acre, or a total of $25,108.50. After some correspondence with Smith, I finally succeeded in inserting a clause, "That in the event of a deal being consuimaated, one-half the amount in excess of the Wyoming Farm Loan Board loan will be due and payable when deal is consummated; the balance shall be due and payable six months from date of initial payment with interest at the rate of seven percent per annum." This option is apparently executed in due and regular form and will, no doubt, hold water. In a letter from Smith under date of December first he states that the balance due the Wyoming Ferm Loan Board is $11,600.00. I had good reason for doubting this statement so wrote the Farm Loan Commissioner at Cheyenne and am enclosing herewith a copy of his letter. If the information contained in the above letter is correct and there is, of course, no reason to doubt it, there is due at this time $15,563.36 on the State loan. This would leave an amount over and above the amount due the State of $9,545.14, one-half of which {the initial payment) will be $4,742.57 due February first after option is exercised; the balance, or other half plus seven percent, Hugust first. You will note after reading Bruch’s letter that the loan is in a very bad condition, and it is not at all unlikely that the Board may take drastic action in the near future if the account is not taken care of If the property was forced on the block, it probably would not bring anything near Smith’s present asking price. �Mr. V/iiiiam. S. Fair. Page Two. This thought has occurred to me: Mrs. Snith and the boys are very anxious to gain possession of this ranch and may be able to finance it if suitable tenns could be arranged whereby they will assume obligations which they can meet. Don’t you believe that so long as the Board is contemplating foreclosure proceedings, that they might be willing to make a new loan in amount to absorb the present delinquent payments, which, according to my figures, would be $15,563.36, and allow Mrs. Smith and the boys to start with a clean slate. The fact that it will be possible to pay George and Adelade Smith in two installments will, of course, make the deal very much easier for Mrs. Smith to finance than if It were necessary to make a payment in full at the time the deal is consummated. I have at this time what I consider a very likely prospective buyer for this property, but have no idea of doing anything with it until Mrs» Smith has had ample time to consider the proposition in its present status. However, as the option is of short duration, I naturally want to get action and will appreciate very much if you can take this up with Mrs. Smith and the boys and let me know of their decision at an early date. In conclusion wish to call your particular attention to my interest in this deal. I will sell this option for a profit of 40^^ per acre which, of course, will add to the cost. Because of Mrs. Smith’s anxiety to control this property before it passes tso others and because of the fact that financing it at this time will be a much easier matter than when she first considered it, in my opinion, makes it a proposition worthy of her consideration. ..--With best wishes to you all, a very Merry Christmas, and with kindest regards, I am, -V ur Yours very truly, h RW/h (Signed) Roy B. Minty _‘J �COPY December 15, 1937 Roy B. Minty Casper, ’.Wyoming. Dear Mr. Minty;- I have your letter regardinrr George E. and Adelaide Smith option which you have obtained covering their ranch located south of Buffalo, consisting of 2643 acres at 59.50 per acre or a total sale price of $25,108.50, I think that George owes $15,563.36 to the Wyoming Farm Loan Board, representing an original loan of $11,600.00 plus delinquent installments. It is reported to me that the B©ard may take some action relative to collection, and the chances are that George will lose his ranch entirely unless he gets busy and sells it to someone, even at a sacrifice price. I feel sure that if Mrs. Margaret L. Snith, and Robert and Alfred purchased the ranch, the Wyoming Farm Loan Board would be willing to transfer the loan to them, providing they made up the delinquent payments. I talked to Alfred a short time ago in regard to this matter, and he said that they had offered George $22,000.00 flat for the ranch some time ago; but that George was asking $30,000.00 for the ranch and that they were so far apart it was believed that they would not be able to get together. I still think that Mrs. Smith and the boys are interested in buying the place, but they will not give $25,000.00 for it. The fact that they recently used considerable of their money for the purchase of some cattle might make it rather difficult for them to swing the deal. The chances are the place will probably go to foreclosure the latter part of this month or some time in January, unless George is able to make some sort of a payment, which I doubt very much if he can do. I suggested to him not long ago that he ought to do scmething about the ranch proposition even if he had to sell it at a great sacrifice and in order to pay off the State Loan and leave him only a small amount for himself, as this would be better than for him to lose everything. I hardly know what to tell you in regard to what Mrs. Smith is able to do right at the present time, but I do know that they will not pay as much as 525,000.00 for the ranch. I believe that if you could get George down to about5B2,000.00 they would raise the money some way or other to buy it; but feel that there is no use trying to move the deal on the $25,000.00 basis. Of course there is not much difference �Roy B. Minty, - 2 - 12-15-37 between the two now as it would only amount to about $3500.00, I think that Mrs. Smith and Robert and Alfred will pay more than anyone else for the ranch as they are familiar with it and it joins in with the ranch of Robert L, Smith. They seem to be the logical buyers, I will again contact Mrs. Smith, and if I hear anything new will communicate with you further. Very truly yours, W. E. W:0a. Vice President. �Deoeaibep 30, 1S37 Mr. George spilth Buffalo, Wyoming Dear George i •• While tb.ls letter may have no particular Intereat to you, X thought It best to keep you advised with refer once to the sale of your ranch. My buyer, wlxo has s’lOTzn a great <^.eal of Interest up xmtil now, has just written that he has changed >11 a alnd; that he Ma liad bo much tt-ne to think, tlint he iiaa concluded to wait until spring when h© Is very sure he can isah© a bettor buy than at tills time, as he has a ilne-up on several pro­ perties that will be on the marlcot between now and spring, Ke also wrote with reference to yours. That wlxlle you might pull youi' propej’ty out of deep water by meeting the demand of the Stat© Land department, it rill ?nly b© temporary relief and that M will watch th© action of the Land Commissioner Rad if your property la handled by thosi with a view to balance the account, he believes he will b© able to buy for considerably less money than hl* last proposition idiioh X handed you a week or so ago* Eafore leaving Buffalo tlw other day I had a talk with Kre« Smith as you suggested, I fouiul thiit she Is interested in the ranch, but if she deals with you for t ho property, sM must have the payzoenta so arx>anged that she oan ^t them when due without causing any hoi’dMhip at the ti^©. If, end when, you are ready to talk business, you may be able to make a very satisfactory deal with Mrs, Smlt’;i, �Mr. George Smith Fage Two I have also talked with Bill Pair regardlxig the ranch and your attitude regarding the sale of eaine. and believe that It would be to your advantage to talk with Bill and get hie "slant” at tills tl ie. With kind regards and best wishes to you all* X am Yours very truly* ROY B. MINTY ��WYO-CISCO “CISCO” GAME REPORT 1932. Date Location------------------------------------------------------------------------------------ ----------- ------------------ -----------------GROSS RECEIPTS: $ Prize Deductions - -- -- -- -- - $ ______________ — Net $ DISBURSEMENTS: “CISCO” Game - -- -- -- -- Operator Total -- - -- -- -- --- -- -- $-------------------------------- $-------------------------------- --- $-------------------------------- Received $--------------------------------- as per above statement, in full payment to date, as per agreement. Operator. > Collector. �NOTICE OF SALE 12-35-600 Commissioner of Farm Loans, Cheyenne, Wyoming. You are hereby notified that of has sold the land embraced in Farm Loan No , to _ ___________________________ the undersigned, of _______________________ (See Reverse Side for Land Description) The undersigned purchaser hereby assumes the unpaid balance of the mortgage indebtedness to the Wyoming Farm Loan Board of Cheyenne upon said premises which mortgage is in the principal sum of $---------------------------------------For convenience in the collection of amortization payments maturing upon said mortgage, it is re­ quested that notice of such maturing payments shall be sent to me. IN WITNESS WHEREOF: I have signed this notice this day of Purchaser sign on above line. IN PRESENCE OF: Postoffice , 19___ � https://caspercollege.cvlcollections.org/files/original/8c00259d6a9392cd5454c443b53abdc3.pdf 9a2ad9d1165a2a96650f14bc75ba640a PDF Text Text THE COMPANY WILL APPRECIATE SUGGESTIONS FROM ITS PATRONS CONCERNING ITS SERVICE Class of Service This is a full-rate Telegram or Cable­ gram unless its de­ ferred character is in­ dicated by a suitable symbol above or pre­ ceding the address. 1201-S WESTERN UNION"" R. B. WHITB PRUIDSNT NEWCOMB CARLTON CHAIRMAN OP THE BOARD J. C, WILLBVKA _____________ PIRBT VICB-PBEBIDBMT The filing time shown in the date line on teleemns and day letters is STANDARD TIME at point of origin. Time of receipt is STANDARD TIME at point of destination. Received at 138 North Center St., Casper, Wyo. VA'125 7 XC-BUFFALO WYO 6 1048A ROY B MINTY- . HENNING HOTEL CASPER WYO- HAVE NOT BEEN ABLE TO ARRANGE FINANCEROBERT C SMITH. ” • THERE IS NO DEPENDABLE SUBSTITUTE FOR WESTERN UNION TIME JAi\i 6 Af^ H 20 ��k"- Z’, �Febimax^ X98S Mr. Oeorge Smith i>uffalo« Wyoming Doav George! * Please accept my apologies for not replying to your letter^ but X have be«i usable to OTito because of th© fact I have been on my back with what the doctor diagnosed as a heart attack,and all they will let me do la to continue to lie on toy bank and keep my xoouth shut* So far as tl^ ranch deal la ooncemed* X am afraid ti:er© Is not zaueh doln^ as th© bottom seems to have dropped out and It Is hard to Interest anyone In anything* I am firmly convinced. However, George* that iSrs. Smith and tlie two boys are your beat prospects. I have had two conversations with her and If they would purchase the ranch on terns which they could meet* I am very certain that you could make a dealt but they positively will not obligate tiismselves in any way which will make It difficult or uncertain In makShig such oulf nations. I feel quite sure that if you could talk to Mrs, Siilth and the boys and could arrange some sort of a plan wiieroby you could agree on a monthly payment which they could meet* that It will be your best bet* Of course. If such an agroenient Is reached* it will have to be after a conference with the State Board with reference to th© delinquent payments for a new plan adopted whereby lira. Srilth and lie boys coi:iXd work it out* With personal regards* X am Yoxirs very truly* ROY B* MDiTX �July 12, 1958 Mrs. Margaret Smith Occidental Hotel Buffalo, Wyoming My dear Mrs. Smith:-* 1 have been unfortunate enough to be compelled to remain away from my office for months, consequently have been out of touch with everything that has happened. I am glad to say, however, that Dr. Kamp has turned me loose on condition that I promise to be good; and from now on ojqjeot to be on the Job. George Smith was Just in and gave me the inforaation on the ranch deal that was consummated on April Sth, and that you and tlie boys are now in possession of the pi»operty. You, .no 'doubt, have been very busy and have not had time to give me much consideration which, I believe, under the circumstancea I should have been shown. Cf course, Mrs. Smith, you are familiar with the time and details that v/ere necessary in consummating this deal so fart as my part was concerned) and I am sure that when you give this matter tliought that you and the boys will write me fully with refer­ ence to the commission as earned and as per agreement between ourselves. I am very glad Indeed that the boys are in possession of this property and that it la all back and held Intact by your family; and with two such boys as you have, they should hit the high spots in due time. With kindest personal regards, I am Yours very truly. RBU/h ROY B. MiNTY �ROBERT C. SMITH BUFFALO. WYOMING July SOth, 1938 Mr. Roy B. Minty: Casper, V/yoraing. . Bear Mr. Minty: lour letter received and I am Indeed glad to know you are atiaui; eoxc to ce at une oiirce; i or v/nen Rooert was in Casper a few weeks ago and called at your office he was sorry to find you were not able to be down, I was surprised tc know that .you expected a commission on the deal which we made on the ranch; for we had as I explained fully to you, given up the idea of that deal when we bought the Work’s cattle and mountain permit which used up all of our available finance. The boys after one season ranching, had decided they needed stock more then another ranch, much as they would liked to have George’s place, but they couldn’t swing both. It was not until Mr. Fulkerson came in itoril that we learned after he had talked with George that a deal could be consummated with no down payment. George takes $100.00 monthly payments and the State one deficit payment each year until the loan is brought to date. Of course, this was a surprise proposition and one they could not pass up. 1 .very much appreciate your efforts in our behalf and as you recall, when you interviewed Robert and me in Dec.THT asked to pay you and especially for telephone c? ^2s , or other e?:nenses, which you would not let me do. However, I still feel you should be paid for expenses incurred for us, arid I am enclosing my check for $50.00 to coVer same. u ’ I most sincerely hope your helth wij.! continue to Improve and with kindest regards to Mrs. Minty and yourself, I am Very truly yours. �OWMEWglB ESTABLtSHeo 1893 W. E. FAIR VICS PRESIDENT July 21, 1938 Mr. Roy B. Minty Henning Hotel Casper, Wyoming Dear Roy: I am enclosing herein copy of a letter which I wrote to you September 20, 1937, and also a copy of a letter which I wrote to you December 15, 1937, concerning the prospect for sale of the George E. anith ranch to Margaret L. Smith and her sons, Alfred and Robert. I am also enclosing a copy of the letter irtiich you wrote to me. This appears to be all of the correspondence which we had concerning this transaction. I hope that these are the letters you had in mind. I regret to hear that you have been ill, although recently B. H. McCarthy told me that you had been "laid up." WEF:L Vice President �July 25, 1958 Mrs* A. M« Smith B^^ffalo, W/omljig Dear Mrs. Smith:I am just in receipt of ,zoup letter and appreciate very much your interest In my pre­ sent state of health. 1 am ^lad to say that I feel better every day and hope soon to be at least somewhere near normal* I was rather surprised and disappointed in your attitude with reference to our ranch deal. I have been joing over the correspondence carefully since rceeivin<5 your -setter,from the date you and Albert called on me in August with the ranch pro­ position in mind. At the time this deal started you were most anxious tiiat George Smith should not kxiow of your interest, so the result was that we created a phoney buyer and proceeded aloi^ those lines, keeping you and the boys out of the deal so far as George 5mith was concerned. You stated that the deal which was finally consiuamate whereby George receives ^100 monthly and you to pick up the deficit payment each year was a surprise move. I’or your information 1 am quoting a letter I wrote to George the first of February and after I was taken sick: "I am, however, firmly confinced, George, that Mrs. Sralth and the two boys ax*e your best prospects. I h .ve had two conversations with her recently and if they could purchase the ranch �Mrs* A* M. Smith Pai;e Two on tenaG that they could laeet^ 1 am very certain that you could make a deal; but they positively will obligate themselves in no way which v/ill make it difficult or uncertain in meeting such obliga­ tions. I feel sure that if you will talk to hrs. Smith arid the two 'ooya> you can arrange some sort oX‘ plan v/hereby you could agree on monthly payments which they could meet, that it will be your best bet. ”0f course, if such an agreement is reached, it will have to be after a conference vrif; the State Board with reference to the delinquont payments whereby a nev/ plan vrould have to be adopted which lira. Smith and th© boys could work out.” It 13 very true what you say, Mrs. &&ith, that In December you offered to pay me enough to cover my expenses Incurred on this deal which, of course, I would not permit, advising you at tlje time that if the deal was not consummated that you would not owe me a cent; that X would have nothing earned unless we could close the deal. You then asked me about wiiat the amount might be and I stated that a regular real estate brokerage would bo 5>i» on the first ^10,000 and OSi/o on the balance which would make a total of approximately §800; but that 1 would trim this amount to fit the picture and be satisfied with that px’ofit and X had in mind that I would cut the amount into because of the existing circumstances and the difficulty in financing the deal and your earnest desire to have the property bacx in thv faijily. I amde several trips to Buffalo In connection with this matter and after you advixed me not to call you through the Bihfalo exchange, I dound it necessary then to drive up to see you which, of course, was further expense. �Mrs* A. M« Smith Pogo Three Mrs* Smith, please believe me when X tell you that I have no intention or desire to be or seem unfair in this matter with you or the boyjt, but at the same time i do feel that I am entitled to the amount indicated above because of tiie facts already stated that If there was no deal, I would earn nothing* I hope that this letter, and th.?,t this deal of ours, will not disturb in any way a nice friendship of such long standing, and regardless of the outcome, so far as I am concerned, I will alv/ays have the same friendly feeling for you and your family* Sincerely, Rm/h R. B. MINTY �September 6, 1938 Mrs. A. M. Smith Occidental Hotel Buffalo, Viyomlng Deer Mrs. Smith: I, of course, am intelligent enough that I am being ignored, totally disregarded, except your check for ^50 which was duly received. had this $S0 been suXTlcient to cover my expenses which, of course, you kpow it wasn't, I still contend t^t 1 c^not continue in business without receiving an amount equal to my expenses, plus a profit. This matter of overhead is an item wh^oh goes on forever and one with wnloh I am sure you are fully acquainted. You are conducting a hotel and giving hotel service for a fixed foe. Supposing a guest reglatered^ln at your hotel and is assigned to a room ior «'"tch the rate misiit be per &a.j and if when that guest chocks o^t, e chSoses to >ay you SOii' for such room and service - ’^®re will a person get and how long will he remain Ir. business? How, Mrs. Smith, I still feel and always will, that I handled vour prooosltion as well as anyone could and that I ”ave It a great deal of my time and attention and i secured results, for which 1 ftxa entitled to pay. Also, it aornetlmea auiuobxuwD happens, '***•*J as In ~ _ _____-a. such service as is requested of me and for i^loh I am not oaid, paid, it la because a client is less enthusiastic after such service has been rendered ^d results accomplished, than such client may have been when they arranged for such service• This particular deal terminated exactly as planned and as you requested and if you still are not inclined to p^y M for^my servlcos, you should, in my opinion, nt lea.t so^ mo a check to cover in full my e^ensos for aerviooa rendered directly to you. Your 8 very truly. Roy Be Minty m/s �September 13» 1938 Mtb. a* Me Smith Occidental Hotel Buffalo# Wyoming Dear Mrs* Smithi* X Imagine that It Is only humane, that one should feel as l do* but please understand that I resent very much being so totally Ignored by you with reference to a certain amount of money which you owe me. Mow Mrs* Smith* X am not going i.to derail with you again about this matter. It was clearly tjid definitely ogi'eed th.t nt the time you solicited my services that you would pay me. The amount which I agreed to accept for sucli services rendered,if the ranch deal was consummated was a certain profit on my option secured from Mr. Smith* an amount equal to a real estate broker*8 oommlsslon. rhe legal consnission allowed a I'eal estate broker is five per cent of the fix’st $10*000 and two and one-half per cent of tho balance of the pur­ chase price. ^2*000* The purchase price* approsimately would mean a profit of ^800.00. For certain well-known reasons with which you are well acquainted X agreed to cut this amount loto^and X axfl still willing to settle this account on that basis* but Mrs. Smith X must laicw your deci­ sion by return mail. In conversation with Mr. Fair of the Bank of Commerce a day or two ago, he infomed me that you agreed to take care of this mattei* at the �Mrs* A* M* Smith Page Two time you were conferring wlch him nt the Bank of Commerce* and at which time he called me on the tolephone. The phono conversation being later con- . firmed by letter and I feel that I am personally within my rights In asking you for an Inaaediate settlement as per above* X am not seeking alms* nor am X a subject of charity, I am »1 ply aUcIng you fir a settlement as agreed upon before negctletions wore opened with George llmlthtsnd at which time you and Albert came to Casper to see me for not other reason than to make an effort to purchase th© George Smith rancho for you^ vlth the perfect understanding that you and the boys were to be kept under cover. I will not write you again* Mrs. hnith, nor will I annoy you with this matter directly, but if I cannot hoar from you by return mall, I will put it in other hands* Xt is too bad thtt this matter should terminate in this way, but as I have already stated I am perfectly justified, and I thoroughly dislike being 30 utterly Ignored while d mandlng only what is rightly due me. Yours truly* ROY B. MINTY �ROBERT C. SMITH BUFFALO, WVOMINO Sept. 15, 1938 LIr. Roy B. Minty Henning Hotel Casper, Wyoming Bear Mr. Minty: I am very sorry that yon feel that I have ignored, yonr letters, hnt I thonght that my letter of July 20th covered, the matter thorcnghiy. I regret that we d.o not see this matter in the same light, hnt it is im­ possible for me to agree\to yonr demands. Margaret L. Smith �E.E. Enterline Madge Enterline LAWYERS WYOMING NATIONAL BANK BUILDING CASPER, WYOMING Deoember 13* 1938 Mr. Roy B. Minty Casper, ■Wyoming Dear Mr. Minty: We took up with Mr. Shumaker the credit which you were under the impression was due you from the Andrews note. Mr. Shumaker explained the transaction as follows: Upon the date you paid the note, Septem­ ber 23rd, 1937, there was due on the principal t505.21 and $75.91 interest, making a total of $581.12. You paid $495.21, leaving a balance due the bank of $85.91. Since that time the bank has received $47.50 through the Credit Exchange on the Andrews note, so that there is still a balance of $37.41 they have not collected on your note. Mr. Shumaker informs us that the bank paid the Credit Exchange one-third of the amount colleoted on the Andrews note for collection fees. We are returning cancelled check and data left with us by you and figures furnished us by Mr. Shumaker. Very truly yours, ENTERLINE & ENTERLINE By ME:dz Enc. �E. E.ENTEMLiNe Madgk Entkruinb LAWYE RS WYOMING NATIONAL BANK BUILDING CASPER, WYOMlNO December 13^ 1938 Mr* Roy B« Minty Casper, Wyoming Dear Mr. Minty: Minty v. Smith We have gone over the correspon­ dence left with us in reference to the above matter. W'e do not fool that you have a right of action against Mrs. Smith, although wo can understand why you feel you should have compensation for the services you rendered. We are enclosing data loft with us in regard to this matter. Very truly yours. ENTERLINE & ENTERLINE By MEtds Encl. By �WE APPRECIATE YOUR BUSINESS W()>nxG National ILvnk “SERVICE WITH SECURITY” CasperJVyo. xT O 7 'L- I 'T. I �MEM ORANDUM ROY MINTY �2.8 2 5 6 .5 6 5 5 5 5 5 4 5 4 5 2 5 2 5 2 5 1 .49 •48 •45 •4 5 4 XI XO XO 3 8 3 8 3 7 3 6 3 5 3 5 3 2 3 2 3 1 30 2 8 2. 7 2. 6 2 4 2 4 2 4 20 J.7 J.7 J. 6 J.5 J.5 J. 2 9 6 5 1 8 .8 0 * �------------------ <S“ -------- ------------- cT^ ■ -----y-S k- r 5^ __ —--- -t" 1^c J" 7J h L~i7-) ----------- 1:, ------- iT j) b /} y—i —' +- ,----- 5^ /- 7-'^-7^. b j Y-^ u 0 7 b- .— / O _ •?^ ^g fa - f ------------ ------ 7^ — - 5“ //- 2-T-^ fe — ii!' 17-^ / - 7 Y ~ ■1) ,3.^‘i-ih ’tc- ft"-i1 -?!<■ — \/> I-I'- yi r-,r — �Casper,Wyoming, 193 jL„ AF The Wyoming National Bankof CASPER, WYOMING. L ( -DOLLARS, i PAYABLE AT THE OFFICE OF THE WYOMING NATIONAL BANK 0 I I ON AT THE RATE OF~ ASPER, AT CASPER, WYOMINGyW>TM-+NTERE LY,AND WITH ATTORNEYS A^TlC<|gTO PER CENT PER ANNUM FROM DATE UNTIL PAID, PAYABLE SEMI-ANN COSTS IN CASE PAYMENT IS, NOT MADE ACCORDING TO TENOR AT MATURITY, WAIVING BENEFIT OF STAY AND EXEMPTION LAWS.. //HE' drWer»d en RS SEVERALLY WAIVE .PRESENTMENT FOR PAYMENT. PROTEST. AND NOTICE OF PROTEST, AND NON-PAYMENT OF THIS NOTE W® W® ALL ALL 'DEFEff^ES ON TVft BROUND OF ANY EXTENSION OF THE TIME OF PAYMENT THAT MAY BE GIVEN BY THE HOLDER OR HOLDERS TO THEM OR EffWER OF THEM. ' ' ’ DUE NO. 193 �WE APPREi^rA I E.-YOlSR 'BUSINESS Wyoming National Bank ••SER''ICE WITH SECURITY” E MftU.« SE»vE^ Casi»er,Wyo. ?1 ~ /i 6- ' S- -■ S- 5 S ! J ■ .6 0 �M EMORANDUM iictn ROY B. MINTY 3L-- � https://caspercollege.cvlcollections.org/files/original/5267dff256e4eb5de6467b68de5b5b4e.pdf 147f4d94c938eac5e6776e7f97a64875 PDF Text Text February 21, 1939 Mr. H. B« Durham Wyoming Natl Bank Bldg Casper, Wyoming My dear Sir:- Referrlng to my claim against Mrs* Margaret Smith and sons of Bxiffalo, Wyoming* I have already handed you the file contain­ ing such correspondence as 1 had referring to this matter, but unfortunately the correspondence does not cover this matter in detail as there were so many conferences, both in my office and at the Oc­ cidental Hotel, Buffalo, as well as by long distance telephone* i will try to state as briefly as possible, for you, what occurred from the time I was first approached by Mrs. Smith and her sons regarding this matter* Sometime during the month of August, 1937, Mrs* Smith and one of her sons, Albert, Came into my office and stated that they had a proposition to submit to me and were soliciting my assistance with the same. At the time Mrs. anlth* s husband died he was In partnership with his brother and they were owners of an extensive ranch on Crazy Woman. Wlien the Smith Estate was settled the ranch was divided equally be­ tween the L. Smith Estate and George Smith, the sur­ viving brother* This was also true with such stock as they owned at the time* Mrs. Smith’s sons, Gilbert and Fobert, with Mrs. Smith took possession of what was known as the "Lower Ranch" and Robert continued to operate It* �Mr. H. B. Durham Page 2 After making the above explanation to me, Mrs. anith stated that George Smith had made more or less of a failure of the ranch ajaljiat which was a heavy State loan amounting to‘7?ourteen some thousand dollars. Including several delinquent payments; and that at the time she was in my office he was negotiating with a prospective buyer to sell his half or what was known as the "Upper Ranch," which was divided from the "Lower Ranch" by a wire fence. Mrs. Smith was very anxious indeed to gain possession of this and not allow it to be sold outside the family; that if she could get possession. It would make a ranch that the other boy could operate, thereby setting up both boys on good ranches which property was covered with probably the best water right in Johnson county. Because of the ill feeling existing, she was most anxious that George &nith,(her husband’s brother) would not be advised that she and the boys were prospective buyers, she believing that if he knew that they were anxious to get possession he might moke it pretty tough for them because of the fact, as Mrs. Smith explained, there was a good deal of hard feeling at the time of the division of the property, George Smith still feeling that he had the worst uf the deal; and Mrs. Smith stated several times that it was moat Important that George was not advised for fear he might not even consider Mrs. Smith and the boys as buyers. After discussing the matter at some length, it was suggested that I secure an option from George Smith Immediately so that he could not dispose of the property except through me and, thereby, give Mrs. Smith and the boys an apportunity and time to consummate some sort of a deal through me. At that time Mrs. Smith and Albert both stated, not once but several times, that they would pay me what it might be w irth should I get this deal over for them. �Mr. H. B. Durham Page 3 I secured an option as per file in your office. I had some correspondence with Mr. Fair of the Bank of Commerce In Sheridan regarding the matter and several long distance telephone calls in which he stated that Mrs. Smith had agreed with him that I was the logical one to work on the pro­ perty and that Mrs. Smith had agreed with Mr. Fair to pay mo a profit on my option. After working several weeks Mrs. Smith be­ came alarmed fearing that George Smith might learn through some slip that she was the prospective buyer and asked mo not to call her long distance telephone as she was afraid some infoinaatlon might leak out from the telephone exchange in Buffalo. Thia made it more difficult and more ejtpenslve for me because there were matters coming up constantly which I had to discuss with Mrs. Smith and, due to the fact, that I could not call her long distance. It necessitated several trip to Buffalo* At one of my interviews with Mrs. Smith in her apartment In the hotel, she again stated that she would pay me and asked me what the approximate amount might be. I replied definitely that as 1 had no real estate broker's license, that I could not handle the matter on a commission basis and the only thing left was to sell her the property at an advance over my option which might cover a reasonable profit. I also explained to her t^t the legal commission In such transactions was 5^ on the first §10,CX)0 involved and on the balance which would make a profit to me of about $800 depending, of course, on the sale price. She signified to me at the time that It was satisfactory and I had no reason to believe that It was not until later, after the deal was consummated and she reneged. My option expired February 1st, and January 14th prior to February Ist, I was taken ill and for a long time was unable to attend to business, although 1 did write George Smith a letter from the hospital where I was confined, outlining a proposition that he might �) Mry H* B» Durham Page 4 / work out with Mrs, Smith (in the meantime he had learned that Mrs, Smith and the hoys were my prospective buyers) on a basis which would bo sat­ isfactory to her and which obligation she would bo able to meet from other incomes* u While I was still 111, thoy consummated this deal on the basis of the proposition that I / ,had submitted to George* y- ' .y n I I h /' / • i ' / , I j / / r /i A I /! j\ fl j\ i I //i yn ■ I i' y /: /; I : ' ' 1 wish to state, also, that George Smith had agreed that he would extend the option anytime I asked him to If I received any encouragement from my buyers and more time was neoessairy to work out the details* IXie to illness, I remained away from the office until about September 1st, and I was never advised by Mrs, Smith that she had consummated thia dealj and when I wrote her regarding the matter she replied as per her letter In the Smith file which is in your possession* In my opinion. It was a contemptable thing Por them to do* fhey had solicited my assistance and I had worked five or six months before becoming at great expense and devoted a great deal of and it never occurred to me for one instant that they would not willingly pay me and according to our verbal agreement* I am writing this letter to fill in the gape that are apparent In our correspondence, and, that you may get a better and more accurate opinion regarding this matter* Yours very tinily. RBM/h ROY B* MINTY �s f OFFICE OFF LOBBY HENNING HOTEL rC>y b. minty GENERAL COMMISSION WOOL,SHEEP AND CATTLE CASPER. WYOMING February 21, 1959 Mr. H. B. Durham Wyoming Natl Bank Bldg Casper, Wyoming My dear Slr:- Referrlng to my claim against Mrs. Margaret Smith and sons of .Buffalo, Wyoming. I have already handed you the file contain­ ing such correspondence as I had referring to this matter, but unfortunately the correspondence does not cover this matter in detail as there were so many conferences, both in my office and at the Oc­ cidental Hotel, Buffalo, as well as by long distance telephone• will try to state as briefly as possible, for you, what occurred from the time I was first approached by Mrs. Smith and her sons regarding this matter. Sometime during the month of August, 1937, Mrs. Smith and one of her sons, Albert, Came into my office^xand stated that they had a proposition -to submit to me and were soliciting my assistance with the same. At the time Mrs. Smith’s husband died he was in partnership with his brother and they were owners of an extensive ranch on Crazy Woman. When the Oi. Smith Estate was settled the ranch was divided equally be­ tween the Smith Estate and George Smith, the sur­ viving brother. This was also true with such stock as they owned at the time. Mrs. Smith’s sons, Albert and Robert, with Mrs. Smith took possession of what was known as the ’’Lower Ranch” and Robert continued to operate it. �Mr. H. B. Durham Page 2 After making the above explanation to me, Mrs. Smith stated that George Smith had made more or less of a failure of the ranch against which was a heavy State loan amounting to fourteen some thousand dollars, including several delinquent payments; and that at the time she was in my office he was negotiating with a prospective buyer to sell his half or what was known as the "Upper Ranch," which was divided from the "Lower Ranch" by a wire fence. Mrs. Smith was very anxious indeed to gain possession of thid and not allow it to be sold outside the family; that If she could get possession, it would make a ranch that the other boy could operate, thereby setting up both boys on good ranches which property was covered with probably the best water right in Johnson county. Because of the ill feeling existing, she was most anxious that George Smith,(her husband’s brother) would not be advised that she and the boys were prospective buyers, she believing that if he knew that they were anxious to get possession he might make it pretty tough for them because of the fact, as Mrs. Smith explained, there was a good deal of hard feeling at the time of the division of the property, George Smith still feeling that he had the worst of the deal; and Mrs. Smith stated several times that it was most Important that George was not advised for fear he might not even consider Mrs. Smith and the boys as buyers. After discussing the matter at some length, it was suggested that I secure an option from George Smith immediately so that he could not dispose of the property except through me and, thereby, give Mrs. Smith and the boys an opportunity and time to consummate some sort of a deal through me. At that time Mrs. Smith and Albert both stated, not once but several times, that they would pay me what it might be worth should I get this deal over for them. �Mr. H. B. Durham Page 5 I secured an option as per file in your office. I had some correspondence vzlth Mr. Fair of the Bank of Commerce in Sheridan regarding the matter and several long distance telephone calls in which he stated that Mrs. Smith had agreed with him that I was the logical one to work on the pro­ perty and that Mrs. Smith had agreed with Mr. Fair to pay me a profit on my option. After working several weeks Mrs. Smith be­ came alarmed fearing that George Smith might learn through some slip’ that she was the prospective buyer and asked me not to call her long distance telephone as she was afraid some infonnatlon might leak out from the telephone exchange in Buffalo. This made it more difficult and more ej^ensive for me because there were matters coming up constantly which I had to discuss with Mrs. Smith and, due to the fact, that I could not call her long distance, it necessitated several trip to Buffalo. At one of my interviews with Mrs. Smith in her apartment in the hotel, she again stated that she would pay me and asked me what the approximate amount might be. I replied definitely that as I had no real estate broker’s license, that 1 could not handle the matter on a commission basis and the only thing left was to sell her the property at an advance over my option which might cover a reasonable profit. I also explained to her that the legal commission in such transactions was 5^ on the first §10,000 involved and on the balance which would make a profit to me of about $800 depending, of course, on the sale price. She signified to me at the time that it was satisfactory and I had no reason to believe that it was not, until later, after the deal was consummated and she reneged. My option expired February 1st, and January 14th prior to February Ist, I was taken ill and for a long time was unable to attend to business, although I did write George Smith a letter from the hospital where I was confined, outlining a proposition that he might �Mr* H. B« Durham Page 4 work out with Mrs. Smith (in the meantime he had learned that Mrs. Smith and the boys were my prospective buyers) on a basis which would be sat­ isfactory to her and which obligation she would be able to meet from other incomes. While I was still ill, they consummated, this deal on the basis of the proposition that I had submitted to George. I wish to state, also, that George Smith had agreed that he would extend the option anytime I asked him to if 1 received any encouragement from my buyers and more time was necessary to work out the details. Due to Illness, I remained away from the office until about September 1st, and I was never advised by Mrs. Smith that she had consummated this deal; and when I wrote her regarding the matter she replied as per her letter in the Smith file which is in your possession. In my opinion, it was a contemptable thing for them to do. They had solicited my assistance and 1 had worked five or six months before becoming ill, at great expense and devoted a great deal of time; and it never occurred to me for one instant that they would not willingly pay me and according to our verbal agreement. I am writing this letter to fill in the gaps that are apparent in our correspondence, and, that you may get a better and more accurate opinion regarding this matter. Yours vej^y truly, c'zL 4’ M RBM/h ROY B. MII/TO �V z- Kareh 15, 1939, -S: ,‘v^ Mrs, Margaret Smith Bxiffalo, Wyoming - Dear Mrs, Smiths ’.ii been handed to ua for attention, by Minty, correspondence had with you, and a atatoment made relative to servioes rendered you In connection with the _purohaaa ot*, Jthe George Smith Ra«oh<_ After f::olng over these matters and discussing the matter thoroughly with Mr. Minty, we are convinced that you are Justly Indebted to Mr. Minty In connection with this matter. ZZ You have, we are advised, paid him 5^50.00, which Is Inadequate to oven cover the expense Incurred in connection with the matter, to say nothing of compensation for the considerable amount of time, and the several trips he made to Buffalo and some to Cheyenne, In assisting you In securing the purchase of this land. Z^ While it may be true that the transaction was not finally concluded strictly in accordance with Mr. Minty’s option, yet you took advantage of that situation a»a used his services, and you should reasonably compensate him for these services. Before taking any action In this natter, we would like to know what you are willing to do In the matter of making a fair settle^nt with Mr. Minty for these servioes. It certainly Is not equitable to secure one to act for you In a matter of this kind and then not pay for such service. heaw fwew yew yeur early convenience ■ T* Very truly yours. til - A> - - % ■■I zZ'' • y J?’ .S Z;«< 1-* . '2 . V .•‘^. Z <3 �S Prom the desk of— H. B. DURHAM R AT Law NQ 939 in the office this morning ’ of March 15th with refMrs. Smith feels that ind that she' Has no settleily, she must decline to pay Id best wishes, I am Very truly yours, BG:c �BURT QRIGQS Attorney and Counsellor at Law BUFFALO, WYOMING March 17th, 1939 Mr. H. Durham Attorney at Law Gasper, Wyoming Dear Mr. Durham: Mrs. Margaret'Smith was in the office this morning and. asked, me to answer your letter of March 15th with ref­ erence to the claim of Mr. Minth. Mrs. Smith feels that she la not indebted, to Mr. Minty and. that she' lias no settle­ ment to make with him. Consequently, she must d.ecllne to pay anything. With personal regards and best wishes, I am Very truly yours. BG:c � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Minty versus Smith File Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1937-1939 Description An account of the resource File of correspondence between parties concerned in the matter between Minty and Smith. Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Some of the correspondence in this file is from the Occidental Hotel in Buffalo, WY. In other parts of the collection, researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch, information on a Wind River Day School Lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Text Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_MintyvsSmith_1937-1939 Format The file format, physical medium, or dimensions of the resource PDF Extent The size or duration of the resource. 6.81 megabytes (1 folder, 3 files) Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/9d0bfc187b8468d2432f5771c046f67a.pdf bbbb3541e7120f4d442d34aad4bdf670 PDF Text Text UJ H �£va ivuosiva ^oois jaH gesi 8 A 8,uauios4opli3 J«W ^-acmO aH.^ �C A SPER , W Y O M IN G WOOL. SHEEP AND CATTLE G E N E R A L C O M M IS S IO N R O Y B. M IN T Y 4 ��ORiaiNAL ROY B. MINTY GENERAL COMMISSION WOOL. SHEEP AND CATTLE CASPER, WYOMING THIS CONTRACT, made this. day of between M i ^ cka^.l j ..... party of the first, and....( of party of the second part, WITNESSETH: That for and in consideration of the sum of //) ~~ TVotT.ARS; paid by said party of the second part to said party of the first part, in hand paid, said sum being a part of the purchase price, the receipt whereof is hereby acknowledged, said party of the first part hereby sells and agrees to deliver to said party of second part or their assigns i ki j ^...Hampsnjro ....^TTRambouillet . ■' .^TCorriedale .. or an all ewe wether ewe lambs from ewes, bred to or lambs from ewes, bred to ’ rams, lo lamo in Marcn, i Blood .'.rlfambouillet rams, to lamb in April, 19, .^T^^Corriedale j , rams, to lamb in May, 19 *-— .<(^?^ainbouillet Blood all old ewes, .or cut out of herds of first party, in fall of 19 and against which there is no Lien or Encumbrances, title being clear; and now ranging in , unshorn; between the day of...._ ............................ and the day of A. D. 19 at party of the second part’s option (definite date to be determined by second party upon thirty days’ written notice to first party or his agents) F.O^, cars when railroad accepts;s^qj^nt for final destination, weighing and inspection fees paid at .... railway. Party of the first part to order cars/or above sheep. Said sheep to be lotted in dry pens 12 hours off feed and water and to be weighed with dry fleeces; all sheep mentioned in this contract to be in good merchantable condition, to be free from scab and all other diseases; to pass both State and Government inspection. / j Lainl^ gi^pfff^ed to average at least pounds at the price of Zft?,/.. per All lambs under pounds rejected. All sick, crippled, excessively burry, wrinkled-bodied, buck Iambs and long tails to be rejected. Old ewes guaranteed to be ONLY those RAISED by the party of the first part; to be FIRST CUT from herds in fall of to be free from sick, shelly, crippled, ruptured and spoiled bags sheep at the price of per subject to conditions above. Party of the first part further agrees not to otherwise dispose of any sheep, mentioned in above sale, and said sale covers all of this particular class of sheep owned by party of the first part unless otherwise stated. is agreed s mission ai J. c per head will be paid Roy B. Minty, for total number delivered on this contract by party of part at time of this delivery. of IN WITNESS WHEREOF, said parties have hereunto set their hands in triplicate the day date aforesaid. In the presence wit irst Part. of the Second Part. �ROY B. MINTY GENERAL COMMISSION WOOL, SHEEP AND CATTLE CASPER, WYOMING WEIGHT AND TALLY RECORD OF CATTLE SHEEP Lambs Drys Cows -Ewes Bought by_ Bought from Sold toDeliveri On i Draft No. Weight TaUy Tally 1 3 / -■? 0 2 1 2. 3 ' o cs 4 Ho 5 6 Jr 7 JI 10 tl ^0.JJS’JL S'0 •ti iff 70 •/D JrJO it 3e>€>o Weight Grand Touls 33 19 34 Jr 2.y ?ig 23"? 0 M7,$60 J.^1 yz Jz: X r J» JL5*>4 37 38 ! 196 24 25 -JfQ. 1 39 40 J.9 41 19 VJ \3VA0 27 28 29 35 36 22 30 15 Sub Total 32 18 20 Weight 31 xe 26 13 14 2< 23 11 12 17 r> ys* 21 8 9 16 Tally Weight 29 39 No. Head 42 43 44 45 '^60 Kind Price Wh4y TOTAL AMOUNT Less Advance Payment Balance Due .J .. �ROY B. MINTY GENERAL COMMISSION WOOL. SHEEP AND CATTLE CASPER. WYOMING WEIGHT AND TALLY RECORD OF SHEEP CATTLE Bought by_i. Bought from Sold toDeliver* On__ -( Draft No. 1 Tally 4 5 Weight 3/ t 7d 1 H aa 6G 8 ! 12 13 14 IS 7a 3S 2i7a i20 2726 22>i^o 17 70 7a 32 18 33 19 34 20 35 1 fa 23 25 Weight 4, x/y 67a 36 J 22 J 3a 17/a 37 38 lAfa If /7/a 39 40 26 41 27 42 28 43 29 A. 44 ■• 30 Sub Total '■ r. -• 45 - 2Jfi> Weicbt Grand Totals t 17 24 10 11 TaUy Weight 31 21 6 9 TaUy 16 'iS a 2 V'ito 3‘ -Ewes R. R.._- yw 2 Lambs Drys Cows No. Head 7 Kind P rice f hxanvalt '^.■7 TOTAL AMOUNT Less Advance Payment Balance Due 1 . �R O Y B. M IN T Y C a s p e r , W y o m in g W O O L . S H E E P AND C A T T L E G E N E R A L C O M M IS S IO N Pay to the order of. �R O Y B. M IN T Y C a s p e r , W y o m in g W O O L . S H E E P AND C A T T L E G E N E R A L C O M M IS S IO N �Tlie<ii8^ii)er.yalloii<ill5«iiK • * • •• • • • , ___ ISKl 99 31 �ROY B. MINTY WOOL. SHEEP AND CATTLE �ROY B. MINTY ��Octo er 22, 1933 Mr. Claude Wright Mitchell, i^Qorqaka Dear ClaudeJ- After liavliig a very satisfactory conforonoo with Senator O’Mahoney this afternoon, at hl3 rc'^uost I didfeatod the eneloaod. I v/ent inr Into detail with the Senator explaining ovory angle ol our deal. C l** He asked xor this letter as ho is going to Londor towrrow snd will :.mko it his buclnoss to eoe Ur* Stone, the Indian Agent nt Ft. V/aahalcle and id potdiolo, v;iil {_,ot Jin o-iplanation i’roci IJr. as to whgr our contract was not fulfilled. 1 will advise you later of the results* Yours very truly, RDM^X Encl ROY B. MIMPy �ROY B. MINTY GENERAL COMMISSION WOOL. SHEEP AND CATTLE CASPER. WYOMING WEIGHT AND TALLY RECORD OF CATTLE SHEEP •Cows ------ Lambs Ewes Bought by Bought from Sold to Delivered at_ R. R._ Draft Wdght Tal^ Tally a 1 16 ^ZJ 2 17 .?r 3. 18 _____ ■ 4 5 6 Weight TaUy -?75 A J7 31 3/ 33 34 ^7 20 35 u__ 21 36 8 23 :i3 & 6 ^2,7^ 6 7^ -^ 10 11 ' 12 26 13 _____ 6 14 3/3d 34 fd > 15 n 28 38 3^^ 7^ 2 US 6 f :2.?a 25 , _ 37 ^7- 9 ! 19 29 g ^4/ 32 3r 22 Weight — 19 7 Sub Totals 193 39 40 41 42 Idi6 43 f 9^ 44 30 45 '.GO Weight No. Head Kind CXo S3S ____ ______________________________ Price TOTAL AMOUNT Less Advance Pannent Balance Due Amountl 7* / \ �ROY B. MINTY GENERAL COMMISSION WOOL, SHEEP AND CATTLE CASPER. WYOMING WEIGHT AND TALLY RECORD OF SHEEP CATTLE .. Drys Cows Bought by A- w Bought from W, _____________ Lambs ________ Ewes u r-_______ .____________ »t w<- Sa*\________ Sold to------------------------------------------------------------------------------Delivered at S & VY _________________ On_£ AA _________R. R___ —-________________ X ________ iL_____ Draft No. Wdght Tally 1 -2. 7 7 g 16 2 8 5 18 U ! I' a 4 6 » 3/ If 19 / 32 / 3r ii- 21 / i o 34 35 /3 o 2^/e^ 22 37 38 39 25 40 26 41 27 42 28 43 14 29 44 15 30 45 11 ________ t 12 13 3-1 SA Sub Totals No. Head Weight Grand Totals 4^/ G 9 A f /o Price Kind Ar 24 TQTkl^ AMOUNT Less Advance Payment By. 1 36 24 10 VI -------- 33 33 23 I ! f 31 20 — 8 9 if 17 _yj____ Weigh Weight Tally X .kS a *0?’ Amount �Oetoter 86, 1938 non. Joae^ph C. 0*Mahoney United Otrttes Senator Waahlngton, D. C. ISy dear 4enatoriRefarrlng again to our ounreraatloa regarding; th© transaction In lazd>s with ths Pt. Washakie Indians* On or about October 12th, Mr. McFadden, wlio Is connected with the Indian Agent’s office at Ft. tashokle, offered to sell zos 5000 wether l^.nbe and 2000 or raore ovz© lambs, riaklno a total 7000 lambs, plus, ct OCW per poroid dollvorod at Hudson, Wyoming on the Northwostom railroad. I sent Hr. Sj>cncer to Itcndcr to axocuto this contract. Th© contract was mad© with the Wind Elvex* Shoop Assoclntl-m Ft. ’;a:;l?.ahlc, F/t-omlng and clgnod by tlie Assoclation’a president. The Indian L»cpartm©nt refused to accept tho draft for .^5000 on the First national Hank of Mltcliell, Nebraska as advance payment demanding in lieu of t];,e draft a cashier’s check but later passed this detail and demanded instead a casii guai’anto© of §50,000 by th© First Mati;;nal hank of. Fitchell, Neb­ raska to tho First Naitonal bank of Hiverton to jooteot the Indian bepartment against any possible default on the part of ths buyers. Th© bank at Mitchell also this demand. Tho loading dates were set for rny day convenient to th© Indian I>opartment between the 17th and 22nd of October. Th© department made two dellvoriec total­ ing 5359 head which nuaber was 3641 head short of the number stated In the contract. �Hon. J. C. ©’Mahoney Page Two Those sheep were contracted by :ao for the lanb feeder cuptonere of the First National Dank of Mitchell, Nebraska; the bank of course believing that the contract was iron clad and that the laiibs would be delivered, re-contracted these lambs to several of their custoners, making a contract to each individual and collecting as advance payment Ono hollar per head. The banli at fc’ltcholl, of course, is very much put out over this matter as it puts them on the spot witli their custoiaers who had no reason to believe tliiit tlie liLinbs T/ould not be delivered as per contract. Tho bank has now dooided, after due consid­ eration, to compel delivery of tliose lambs even If they have to bring suit. They cannot see the reason for tiie Indian Department malflng such unusual demands for tho protection of tills contract and safe guarding the Indians with absolutely no guarantee or protection for tho buyers. I am perliaps l^sumlng on your time and good nature In annoying you with this matter, but I an at a loss to know \ifhere to go unless to you and If you can give mo any advlco which may lead to a more Just settlomont of this contract to the feeder buyers, it will be very much appreciated. Thanking you, I am yours very truly. RBU/h ROy B. MINTZ �UNITED STATES DEPARTMENT OF THE INTERIOR OFFICE OF INDIAN AFFAIRS Received <rf 5—««2 OFFICIAL RECEIPT N9 476126 Roy B. Mnty,Gasper,'Wyoming. _ ______________ One hundred eighty nine & 15/100 - --------- --- --------- nnT.i.ARj=i. (P. O. ADDRESS) (NAME) Description op Exchange: _ , . . Cashier’s Check No. 3818 dated October 21,1938sDrawn on The i^irst National ^ank,Riverton,vVyo« Paj’able to ^orrest R.St cne, Supt. (FOR MONEY ORDERS, DRAFTS, CHECKS, AND OTHER NEGOTIABLE PAPER, GIVE DESCRIPTION, INCLUDING DATE, NUMBER. ETC.) BILL. NO. QUANTITY FOR WHAT UNIT UNIT PRICE FUNDS TO BE CHARGED AMOUNT Sale of Wind River Day Sciool Lanil)s. as per attached Contract. Remittance, if not in cash, is accepted subject to coilection of exchange. 1484 14-7200. 525: ? of L. Indian Moneys, Wind River Sch Wyo. Total Carribd, (USE PLAIN LETTER-SIZE PAPER FOR EXTRA SHEETS, CITING OFFICIAL 18^ 15 NUMBER ON EACH SHEET) _„Qs.t.Q.her„.24..1938..._________ (DATE) iii8.7,,-Wij?.d..Siv.e.n..lJidl_a]r.^ (UNIT) V. •» •ovRVMKXf nmixo optks ft H«0 .476126 it^^sinQ Officer. �October 1098 Mr. Claude Wright The Firnt national Bank Mltoliell, Nebraska Dear Claudei* 1 vaa very sorry to learn thia afternoon from our phone conversation that Sponcor had neg­ lected to mall you the scale records. I an enclosing same herewith* The record3 were rather confusing as he <3ld not state to whom these lambs were shipped* so I am unable to give you this infornuition, but you probably cap determine who received these lambs fi?oM the enclosed records. X also am enclosing two draft stubs which X found with these; th-ae also should have been forwarded to you along with the scale records* X have heard nothing yet from Senator O’Mahoney but rather eaqsect he will be In today or tomorrow as you know tlie democrats aro putting on a vigorous oampalgn and he la covering the state pretty thoroughly X Imagine* He advised ms while In Casper that he would return In a day or two* You may depend upon ne to ride this matter to a finish* X am Interested also and X don’t like to be put "on ths spot” as In this case. / I will keep you fully advised* ! Very truly yours, KBM^ Encl ROY 3. MiNTY �Hoveaber 1, 1938 Mr. Claude T'rlght Mitchell, liebraeka r>ear Claude:« Ota* mutual friend, Mr. Stone from X^t« V^aahakXa, has Just left my cubby hole. He me, as per usual, very pleasant, most agreeable and extrejiely sorry, so much so in fact, th.-.t he Ixas promised por.slbly three oars of lambs for either Wednesday or xriday. /ts he was not certain of the day I Ixave taken tiie xnatter up wit . tixe il .rthwestern Kailroad and asked them to keep me X'ully advised when these sheep would ruove. V/hen I have tills information 1 will go on to Lander and receive them. Will you in the meantime instruct me as to the billlngt Mr. Stone Is inclined to believe that if he gets tliree cars. It will be the limit, he seeijic very much put out over this matter and blames his sub­ ordinates entirely, leavinsf the impx’ession with me that he thought them moi*e competent and capable of hiuxdllng tills matter tiian they pi-oved to be and stated that another year it will be a different story. I hope that you Ir^ve recovered from your trip around the woi’ld und feel youi’self again. With personal regards, X an Yours very truly. RBM/h IK)X 3. MIKTZ �November’14, 1938 Mr. Forest Stone Ft. Washakie, Wyoming Dear Mr. Stone;I received your letter with reference to the contract with Mr. V/right and immediately forward­ ed same to him for his reaction. Hr. Wright replied lately edvlelng that ha had forvardad a copy of the latter to you at your office, Ft, aahakia. Any further omnenta from me will uroOauly not ba ejected by you after tiw reoaipt of Mr# Wright’s letter. X will state, howewer, that on my last trip to niTertoQ w:wn X recairad tha laat three loade Mr# MoSpaddan stated that there would probably be two more cars this week, or thsy would be available ianodlately after the return oX* on© of the sjenOjere of the association wt;o, at the time, was back east. 1 have been ejcpeotlnf; to have some word fron Mr# Mes^addan with reference to thia ehimssnt. Xt is very plain to understand that Mr# Wright Is on the '‘spot’* with his cuatoaore i.9 liable to them for the non-delivery of these inyabe, oonsoqxaently, no will oontinue to look to you for the eompletioa or a satisfactory adjustment of this contract X wish to take this opportunity to again express ay appreciation of your attitude and your very appax'ent desire to terminate this contract satisfac­ torily to all conoerned# Very truly yours© MOI/ FOX B# MXMTX �laresiber X9M Benatoi’ Joseph C« O*l(ahoaey Senate Offloe Building ffaahlngton* D« G« tf/ dear Senators* This la to express to you ny appre* elation for your efforts In ay behalf with reference to th© Wind river S’leop Association oontn^ot for the purchase of laiabs* Since lay conversation with you tisoy have aodo delivery of three more load a and X on vised tiiat two oo:?© loads will he forth eoalng probably thia wuok. ad* Ur« Wright of the Mrat national Bank of mltchell, Hebraoxe fully realises Ur» ^tone’s positltm in this natter end is not Inclined to be "toxigh", but at the sane tine Mr. '.".'right has obligated hlaself and his baz2k to several of the banks cugtowere from which ooilgutlon there is no release oxoept to either deliver the lax£)s or pay the dosaage* But at thds time there is nothing to de esEcept to wait for further developments. The Aseoela* tlon nay SMke good on this contract* With best vlshea for a ploueont end satisfactory sesoiou this ooming winter with great results for -^yoalngt 1 m Xourc very truly^ BfiUA CC to Mr* Claude wright RCf B. MiKTX �934 005 UNiTED STATES DEPARTMENT OF THE INTERIOR OFFICE OF INDIAN AFFAIRS FIELD SERVICE Wind River Indian ^ency Fort Washakiet Wyoming November 17, 1933. loT* Roy S. WLnty, Henning Hotel, Casper, Wyoming. My dear Mr. Minty: This is to refer to your letter of Noveiaber 14, 1938, concerning oxir contact with you, as Mr* Wright’s agent, for the Sheep Association lambs* '' In checking with Ur* MacSpadden, I find that he was not able to secure any more lambs from Ltr, Winchester, a white man, who he thought might be able to help the association out* As the matter now stands, we have gone just as far as we can without seriously injuring the affairs of the association by encouraging them to make any further forced sales. Under the circumstances, I am compelled to advise you, for the association, that it will not be possible to make any further deliveries. �liovetaber 2S> 1938 Ur« Claude Wright Mitchell, Nobraaka Dear Claudet* X am eneXoslng herevith a letter received from Mr* Stone* It vould seem that they are throur^h and are ’’reRo^l^g’* on the two care that MsSpadden stated would' be' available a week or lore ego. I am ciirloTis to Tenow what aotlnn. If any, 5’ou «'ii*e y^olns to takfi in tills matter. Mr. h. E. Enterline, an outstanding attorney In Casper and Wyoming, might bo a good mon to oonfer with regarding thia deal. Xf, in hie opinion,. v;e i.iiyht Qet a judgiient. It would seem tliat it would be an easy matter to force collection for damages as the Court might allow. But X believe you will agree with me that it Is a matter of which we should have good legal advice before proceeding furtlxer* Xours very truly, Hffil/h EneX ROY B. MJUTT �12626 The First'NA.tio'nai^Bank OFFICERS AND DIRECTORS J. L. SANDFORD. PRESIDENT C. W. WRIGHT. Cashier W. W. NEWELL M B. QUIVEY, Vice president asst. CASHIER W. H. PHINNEY, C. S. CAMPBELL Mitchei.j^ , Nebraska December 1933 B. Minty, Casper, “yoming *^ear Mr. Minty: I have your letter oP November S3rd. enclosing letter from the V»ind ^^iver Indian Agency of November 17th. in which they definitely state that they are not able to deliver the bal­ ance of the contract that we entered into with them under date of October 13th.. Under this contract <1 received on October 19th. 1570 lambs, on October g7th, 1779 lambs, and under date of November 5th. we received 930 lambs, making the total number of lambs received 4179, or a shortage under this contract of 28?! lambs. I am enclosing the contract here'ith, also their letter stating their inability to fulfil the contract and would be pleased to have you take this matter up with Attorney interline, as recommended in your letter. Would like to have you get his opinion and version as to what he thinks could be done, and a statement from hi>i as to what his attorney fees would be. I think this clam should be pushed vigorously if the attorney thinks collection could be forces. Of course, if this cannot be done, there is no use sending any good money after bad. •xe will remit attorney fees promptly for opinion or for services in case suit is started. I shall appreciate it very much if you will take this matter up with him for us. Yours very truly. CVAV/EL �12626 The FirstNationai^Bank OFFICERS AND DIRECTORS President Asst. CASHIER J U. SANDFORD. PRESIDENT M. B. QUIVEY, VICE C. W. WRIGHT. CASHIER W. H. PHINNEY, W. C. $. CAMPBELX W. NEWEU. Mitchell ,Nebraska A-'ecember <5, 1933 Mr. Roy B. Minty, ’^'asper, "’yoming ^ear Roys I am still out of balance $55.11 on the drafts paid for the lambs received from the Indian Agency and I am unable to reconcile the drafts with the weights as furnished, and the difference is on the lambs received in October by Mr. Spencer CM? this contract. For the lambs you ‘ personally received in November, we check exactly with you. I know you have copies of the weight and tally record as furnished us and would be pleased to Tiave you take this item up with Mr. Bpencer. I am enclosing the drafts paid herewith so you will have the whole matter before you. I hope Mr. Spencer can straighten these weights out so they will agree with drafts, but if he is unable to do so, I feel this mistake is his and should be deducted from the commission. iours very truly-j CWW/EB �Dooember 15, 1058 Mr* Claude Wright Mitchell, Nebraska Dear Claude:I nave delayed replying to your last eommunloatlon vlth referenoe to the Indian Deparhuent because 1 have been uiiable to go over the axatter with Mr. Knterline. ’"hile 1 talked to him the day I received you letter, he was just leaving for Cheyenne, and on his return £nom Cheyenne was compelled to be In Court at Lander. He will probably return to Casper Wednesday night. I went over the matter briefly vlth him and he was Interested and advised that he would like to go Into the file and give me an opinion. The minute 1 have this Information, 1 will forward It to you at onoe. While In Buffalo yesterday I heard that several smaller bunches of ewe lambs had sold to feeders at 08/j also, that some ’’wamod-up” lambs from the Sheridan district liad been moved, but X could not get any inxbx^matlon as to the price paid for the "warmed-up" lambs. The cow buyers are still scouting the country for "cannerr " cows and "pody" calves. With jest wlsixes, X am Yours very truly, RBK/h ROY B. MIHTX �Sturgis, S. Dak. Dec. 19,19^8 Roy B. Minty Gasper, Wyo. Dear Roy, I am enclosing herewith the correspondence taken from your files Satuifday, December 17th, also check in the amount of $205»01> which is half of the commission paid by Claude Wright. As you know there were 4,179 lambs delivered, making us a commission of $417»90. When Mr. ffright and I figured up at Mitchell Sunday, there was a diff­ erence of $11.88, between what he paid, and what he received for the lambs. Mr. Wright advises me that the Indian Department acknowledges overpayment, but did not state the exact amount, but advised that you would be reimbursed by the Indian Department. In order to settle with Mr. Wright promptly, I assumed liability for the $11.88, which was subtracted from the $417-90, making a total of $406.02. You may use your own judgment as to reimbursing me for the deficiency. You will isilso find among this pile of junk, my cancelled check in the amount of $12.50, which I paid the First National Bank of Riverton for clearance on drafts given by me. When I told Mr. Wright about this charge, he informed me that I should not have paid it, and would not right my mistake. So if you see fit you might share that with me. I hope this explains the matter clearly. I am also hoping that your attorney gets sufficient reimbursement to cover Mr. Wright’s lose, as well as yours and mine. Next year Ruger can have the Indian lambs • I want you to know that I appreciate your cooperation in this deal and I hope in the future that we may be able to have more and pleasanter dealings. Let me know if anything comes up that I might be able to handle. The best of the season’s greetings to you and Mrs. Minty. �January 23# 1939 Mr* Walter Warren Riverton, Wyoming Dear Slr»- X liave yours of the 20th« First X will call your attention to the first Item on your hill* You Indicate eight oars were Inspected for which you charged the fee of The next Item on October 21st, number of cars not Indicated, you charged $9.00. On November Sth, number of care not Indicated, you charged a fee of ^.50, making a total fee due you of $2i^«00. Your bill might Indicate that you had Inspected 24 oars which. If averaged 300 sheep to a oar. It would mean 7500 lambs. For your Information, I wish to state that this is Just about twice the number of lambs we received from the Indian Department* You might call Mr* UcSpedden*8 attention to our contract, which states very clearly that these lambs were purchased with delivery free on board the care* and until they have been inspected for shipment to certain areas, the railroad company, as you are perfectly aware, cannot aooept them or move them* So, It would seem that It Is up to Ur* UcSpadden to settle your claim. Tours tzMly, ROY B. MINTY rbmA �WALTER WARREN MINNIE A. WARREN IRRIGATED LANDS CITY PROPERTY Warren Reaety RIVERTON. WYOMING JaTiUary 8oth. 1939< Roy Mlat.y, ‘Penning Hotel, Caspsr, Wyon-ing. Dear Roy: I am encloseiag a statement for insrectlons made tn connection with shinring out the lambs produced by the Indians, I did not know that you was conne cted with this" ieal, and was to psy the Inspections, so when T presented the bill to ■Jr. McSpadden recently he informed me that it was in your contract Chat ycpj. was to pay the Inspection, and that when vcu settled the transaction over at the hotel,he mentioned the Inspection and a ■Jr, Spencer, who was looking after your interest in the matter, remarked f^st he would cone ri.^t over and give ms a check,but T suppose he got busy and forgot it< Mr. McSpa'^deivinstructed ne ■’"0 send the statement to you and ’’Ou would settle it« Rn T gm presenting the statement and will appreciate a prompt settlement 30 T can get last years business cleaned up. Appreciating ths bu-^ iness, aad with best wishes, T am. Yours vs^ry truly, Walter Warren. �RIVERTON, WYOMING.JanUq,ry so.th r, Roy Minty, Casper, Wyoming. IN ACCOUNT WITH WALTER WARREN 193a Oct. 1st b,Tn3pectlon and heal certificate 8 oar la Hu nuaSQu, nyo. Oct. 31g . » Nov. 5t 1» J• t■ J. - - $8 50 9 ?0 7 50 5S5 50 These lambs were pxir shased )f ■ he Indians thru the off .08 at i Washakie,«T1 Tria Hudson. W3roTyiing. — — �April £9, 1939 Mr. Claude Wright First National Bank Mitchell, Nebraska hear Claude:* You, no doubt, have wondered f3*oin tliae to time why in H — X have not loade some report with such progress as has been made or perhaps I should say, not been made with the Indian contract. But a lawyer is a hard thing to move, similar to the pyramids oi hgypt, it is a dirficult matter to get action. However, X have reached a point where I must ask for a little fxirther information. In your opinion, what la the amount of damage caused by the failure of the Indian department to deliver the number of lambs as per contract. Mr. Durham, the attorney, has asked me for this information. X am rather surprided to see the feeders from the Valley taking on lambs at this early date. There have probably been some contracted that I know nothing about, but to date there have been 12,000 lambs contracted In the Douglas district and these have been taken by Wright Hamilton, Henry Kurts and Qumpert Brothers. If you and your customers get Itchy, why don’t you let me take on a few In the Casper District? You know we have some swell lambs here and our range conditions ax*e excellent. With kindest personal regards, I am Yours very truly. RBM/h ROY B. MINW �12626 The FirstNationaeBank OFFICERS AND DIRECTORS Vice President Ass t cashier J. L. SANDFORD. PRESIPENT M. B. QUIVEY, C. W. WRIGHT, CASHIER w. H. PHINNEY. W. W. NEWELL C. S. CAMPBELL Mitchell ,Nebkvk ka May § 1939 Mr. i’^oy B. Minty, Casper, **yoming Dear Roy: I have your letter of the-29th.. Relative our loss on lambs contracted with the Indians will say this loss was fully ^^1.00 per head on the number that they failed to deliver. I'he^lacement lambs purchased to fill in cost from 7.90 to 8.25. Please advise attorney Ourham. ■^'he lambs contracted at J>ougiass also surprised us as they were very quiet about their movements on this deal and we did not Icnow of the purchase until the day before your letter was received. From all the evidence we have today it looks as though 3100 were contracted ihstead of 12,000. As to why these feeders should get excited at V^^lambs under present conditions and at this time of the year is too much for me. They undoubtedly have more faith in the general outlook of business for next winter and soring than we have. However, Hoy, if we find any of our customers interested in contracting we will sure refer them to you as we agree with you that there are plenty of good lambs in your territory and will be glad to see you get the business. It is my personal opinion that this is about all the contracting that ?ill be done here for some time an I ain inclined to think the majority of feeders are more interested In seeing how they come out on last years business at this time than in getting started on another deal. Vnhile last years feeding has shown Some profit, however, it is damn small compared with the loss of a year ago and should occasion some carefulness in contracting by our feeders. Trusting this finds you in good health and that the attorney can figure soj^e reasonable way to get action for us on the Indian contract, I remain. Cashier CW“ dbL �I �ADDRESS ONLY THE COMMISSIONER OF INDIAN AFFAIRS REFER IN REPLY TO THE FOLLOWING: UNITED STATES DEPARTMENT OF THE INTERIOR OFFICE OF INDIAN AFFAIRS WASHINGTON MPV ~5 1933 UnUed States Senate. Uy dear Sexiator Schwartz: Thia will refer to your personal Hall at the Office oa May It at which time you requested infomatlon eosoemlfig a oontreot executed by Mr. Hoy B. Minty of Casper, Vi'yoaing, for the eale to Mr. Minty of Iambs grown by Indians of the Wind Hirer Heserratioh. You also left with us a letter ad* dressed to you under date of April 25 by Mr. H. B. Durham, also of Casper, Wyoming, with reference to the matter. We are asking the Superintendent of the V.ind Hirer Keser* ration for a full report In the matter, together with a copy of the contract and other related papers. We shall write you again as soon as we hare reoelred the superintendent’s report. Mr. Durham's letter is returned. SlBoerely yours^ ||» Oemsaloner Snolosure UdMSt �Law Offices of H . B. D TJ RHAM C. NI. Cko'W'bi-3l QOB*11 CoiTSOUSATBS ROYALTY SX>SO. C a.spex*,'Wjroxnirvg May 6, 1939• Mr. Roy Minty, Henning Hotel, Casper, Wyoming. DearRoy; Referring to our telephone conversation a few days ago with reference to the Indian Association contract, I advised you that I had written to Mr. Schwartz in Washington, asking that he contact the office of Inalan Affairs, and give us the dope as to the status of this Wind River Sheep Marketing Association, and also as to how we may proceed to recoup our claim for damages for the breach of the Association’s contract. I am in receipt to-day of a letter from Schwartz, in which he advises me that he has personally talked to the Assistant Counsel in the office of Indian Affairs, with the result that the office advises him that it does not have complete records on the Association, and practically nothing on this particular matter. He states further however, that Mr. Flickinger, Assistant Counsel of Indian Affairs, is directing the field office to make a complete report on the matter, so it may be determined what, if any, procedure lies open to our clienl for recovery of damages on this contract against the Indian Assoc­ iation, and he will report just as soon as this information is se­ cured. I hope that out of this we may be able to develop something that will furnish us an avenue for securing settlement. Very truly yours. HB D/A � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Wind River Day School Lamb Sale File Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1938-1939 Description An account of the resource The Wind River Day School Lamb Sale file contains correspondence and financial from 1938 to 1939. Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch, as well as ledger books, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Text Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_WindriverDaySchoolLambSale Format The file format, physical medium, or dimensions of the resource PDF Extent The size or duration of the resource. 3.58 megabytes (37 pages) Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/ca3f92a68a6cf64d8ff22c1121d7185f.pdf 0d7427d19c81c3fc36d6d047950185d7 PDF Text Text Form 1206A y CLASS OF SERVICE DESIRED CABLE OOMESTIC TELE'iRAM FULL RATE DAY Lt H ER DEFERRED NIGHT CABLE LETTER MESSAGE NIGHT LETTER X WEEK END LETTER I’atrona should check claaa oi service desired; otherwise measage will be transmitted as a full-rate A communication ( WESTERN UNION NEWCOMB CARLTON, PRESIDENT J. C. WILLEVeR, FIRST VieC'PRCSIOENT Send thefollowing masage, subject to the terms on bacJi hereof, which are hereby agreed to January 3, 1934» Choate, Hall & Stewart Attorneys at Law 30 State Street Boston, Massachusetts For lirj'edlate settlement Minty versus Draper & Company Minty authorizes settlement six thousand dollars (stop) Amount duo with interest considerably exceeds this sum but for quick settlement and to avoid trip to Boston compromise is acceptable (stop) If above settlement cannot be made Minty can leave for Boston within week If trial can be arranged> Advise. jOTRHAM & BACHELLER (Charge Durham & Bacheller) �October 10, 1933. Choate, Hall & Stewart Attorneys at Law 30 State Street Boston, Mass, Rea Minty va. Draper & Oonpanar, Gentlemen: . VZe acknowledge receipt of yours of the 3rd In the above matter. Mr, Minty is out of the city, but as soon as he returns and we have had an opportunity of discussing the matter with him, we feel that we will be able to submit an offer In con^romise. As soon as we can contact him, we will write you further. Very truly yours, ., - �CHOATE, HALL & STEWART JOHN LHALL FREDERICK H.NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O. PENGRA HARVEY H. BUNDY CLAUDE R. BRANCH JAMES GARFIELD CHARLES P.CURTIS, JR. RICHARD C. CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT 30 STATE STREET CHARLES F. CHOATE. JR. TELEPHONE HUBBARD 5020 1899 - 1927 RALPH A.STEWART I9OA ~ 1928 BOSTON. MASS. October 5, Messrs* H* 5* Durham and E. P* Bacheller, Casper, Wyoming* Dear Sirs: In re; Minty v* Draper & Ccnapany I have not previouslyreplied to yonr letter of September 13th because until today I have been un­ successful in getting an audience with Mr* Hughes, attorney for the defendant. I have been trying for sometime to get Mr* Hughes to agree to the taking of Mr* Minty*s deposition upon oral interrogatories. While he has never definitely refused to do this he has always had some good reason for postponing his decision. It now appears that he is anxious to get the $7500* which weare holding under attachment re­ leased by giving a bond and I think I may be able to get some sort of an agreement in the very near future Today, inc onnectlon with the release of the attachment a discussion of a possible settlement came up and he has requested me to give him our best settle­ ment figure. He said he did not know whether his client would be willing to settle the case but he would be glad to submit to them any reasonable figure we might name* As I wrote you before, regardless of whether or not Mr. Minty*s deposition is taken I think It will be necessary for him to be here for the trial as there is almost sure to be evidence offered by the defendant which we would want Mr. Minty to contradict* In view of the expense Involved I assume Mr. Minty would prefer to settle the case if a reasonable offer is made by the defendant. Will you please discuss the matter with Mr. Minty and let me know the lowest figure he would be willing to accept. Of course, I shall try to get as much as I can but I would like to know what his lowest figure is* Very t3*uly yours. SPT:JLG �4-^7 ’•r»tember 1933 \ ChoatOf Hall & Stewart 30 State Street Boston, Maae* * In re> Minty vs. Draper & Company* GentXement We will be pleased to have yon advlee US the present statue of this matter, as client Is Inquiring, Very truly yours, DURHAM & BACHELLER, -'—Al- �April 27, 1933. Choate, Hall Stewart Attorneys at Lav 30 State Street Boston, Mass. In z*ei Minty vs. Draper & Co, Gentlemen: It has been some months since ve have heard from you oonoemlng the status of the above litigation. Will you please give us a complete report at this time so that we may bring our files up to date? Very truly yours, DURHAM & BACHELLER, By SPBiW �Way 19, 1933. Choate. Hall de Stewart SO State Street Boston, Mass* In ret Minty y» Draper & Coinpaig. Oentlenwi! We acknowledge receipt of yoitrs of the 15th In the above jnatter. W© note that a Tnotlon will be made to permit the taking of the testimony of the plaintiff orally at Ceaper. Many times. In the taking of a deposition upon Intorrogatorles, ancwers suggest further questions which cannot be propounded unless the deposition Is taken orally* This Is one of the ndvantagos of an oral deposition, and w© trust that you may be successful In your contemplated motion* We Intend to xa*G© very strongly upon Mr, Minty the alvleablllty of planning to appear per­ sonally In the trial of the action, and we sincerely hone that be ?p«ty b© n>le to make the necessary financial arr«3n^*»ment8 to attend. Vex*y truly yours, DORHAM & BACHBIXER, By BPBtW �CHOATE, HALL a STEWART 30 STATE STREET JOHN L.HALL FREDERICK H.NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O. PENGRA CLAUDE R. BRANCH JAMES GARFIELD CHARLES P. CURTIS, JR. RICHARD C.CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT CHARLES F. CHOATE. JR. TELEPHONE HUBBARD 5030 1699 - 1927 RALPH A. STEWART 1904 - 1926 BOSTON. MASS, Messrs. Durham & Casper, Wyoming. lay 16, 1953. Bacheller, Dear Sirs: In re; Minty v. Draper & Co. Receipt is acknowledged of your letter of May 10th. I note what you say in regard to the demoralized condition in the wool and sheep market and that Mr. Minty would probably not care to incur the expense of a trip to Boston. As I told you in my recent letter it does not now appear likely that the case will be reached this year, and I hope by the time the case is ripe for trial things may have so Improved with Mr. Minty that he will be able to come here to testify in person. However, as you suggest, no Hr rm will come from taking the deposition at this time even though Mr. Minty should later decide to come on. Our courts have power to permit the taking of oral depositions but where there is strong objection by either side the parties are usually required to take the depositions on written interrogatories. In this case I can see considerable advantare to taking the deposition of Mr. Minty orally and I shall make a motion to that end and urge the same as strongly as I can. Very truly yours. SPTzJLG �May 10, 1933 Choate, Hall & Stewart Attorneys at Law 30 State Street Boston, Mass* Gentlemen: ■V© r.ekno^^ledge reeetpt of yours of the Sth In the matter of Minty vs, Draper & Gompany, and note the congestion of your docket. Mr. Minty Is not In Casper at the present time, so that we are tinahle to confer with him personally with reference to the second paragraph of your letter. However, we are confident that ho will not care to Incur the expense Incident to a trip hack to Boston, hut would prefer to have his deposition taken here. We realize that his personal presence In court would add materially to the strength of his case, hut the demoralized condition existing In the wool and sheep market for the past several years has made economy the watch-­ word of all engaged In th© live stock Industry, and wo are confident that If the case should he reached for trial this spring Mr. Minty would not care to make th© trip. However, wo presume that ©ven though the deposition may he taken. If Mr. Minty should later decide to make the trip ho would not ho precluded from testifying. We note that the deposition Is to he taken on Interrogatories, and wo are wondering If, under your practice, this Is necessary. It might ho more satisfactory to give notice of th© taking of th© deposition before competent authority at Casper, with the thought that In this way the deposition mlrht possibly bo more thorough In covering Mr. Minty’s testimony. However, we will be governed by your surrestlon, of eou'^’n©. It Is unfortunate that the trial will, of necessity, he delayed for some time, but such delay seems unadvoldahlo. Very truly yours, DURHAM & BACHELLER, By EPBlW �CHOATE, HALL a STEWART 30 STATE STREET JOHN L. HALL FREDERICK H. NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O. PENGRA CLAUDE R. BRANCH JAMES GARFIELD CHARLES P. CURTIS, JR. RICHARD C.CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT CHARLES F. CHOATE. JR. TELEPHONE HUBBARD 5020 1699 - 1927 RALPH A.STEWART 190-4 - 1926 BOSTON, MASS. May 5, 1953 Messrs. Durham & Batcheller, Casper, Wyoming. i^ear Sirs Ip re: Minty v. Draper & Company Replying to your letter of April 27th with reference to the status of the above case I will say that this action is pend­ ing on the general jury list for Suffolk County, being No. 279415. There are several thousand cases ahead of the Minty Case so that there is very little prospect of it being reached for trial this year. Within the next few wceRs I intend to prepare interro^atories for the purpose vf taking hir. Minty’s deposition unless vou think it will oe practical for him to come on here at the time of the trial. Of course, you appreciate that Mr. Minty’s testimony on the witness stand would be much more effective than his deposition but, on the other hand, I realize that for him to come on here would involve considerable expense. I shall leave that matter entirely up to you and Mr. Minty, although if he cou^d be here at the time of the trial I am sure it would be of considerable help to his case. At the time suit was brought against Draper & Company wo made an attachment by trustee process and have under attachment $7,500. which Is the amount of the ad damnum alleged in the writ, therefore, should we be successful in the suit there appears to be no question about payment of any judgment we may recover. The defendant claimed jury trial so that we can not. without the defendant’s consent, waive plaintiff’s claim for jury trial and get a speedy trial by the court. Very truly yours. SPT:JLG �July 11, 1938. Choate^ Hall £: Stewart Lttoi'neya at Lav 30 State Street Boston, Maee* Eet Minty VB» Draper & Company* Gentlemen: Answer to your letter of the 26th ult. has been delayed beoauae X have been out of the olty* Mr* Minty has a complete x^eeord of all sums dlBbui*oed by him for filing feee, and these i;ecords will be available for uae upon the tiding of his deposition* Very tznxly yours, DURHAM & BACHELLER, EPD-.W �CHOATE, HALL & STEWART 30 STATE STREET JOHN U. HALL FREDERICK H. NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O. PENGRA CLAUDE R. BRANCH JAMES GARFIELD CHARLES P-CURTIS, JR. RICHARD C.CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT TELEPHONE HUBBARD 5020 CHARLES F, CHOATE, JR. 1699 - 1927 RALPH A.STEWART 1904 - 1926 BOSTON, MASS. June 28, 1932 Messrs. Durham & Bacheller Casper, Wyoming Re! Minty v. Draper & Co., Inc. Gentlemen: Thank you for your letter of June 25. The figures which were In the copy of our, declaration which was sent to you were taken from the declaration prepared in your office, and I assume they are correct. Did Mr. Minty keep any records of the sums disbursed by him for filing fees? The file which we have contains no Itemized statement of the amounts so disbursed by him. Thank you for your explanation of a telegram of February 4. I feel this telegram is somewhat ambiguous but it seems fairly clear, with the exception of the matter of expenses. Very truly yours �Juno 25th, 1932 Choate, Hall & Stevert, 90 State Stx*eet, Boston, T^aBsaohusette. 2S3L.^> i* j»s.cgr & Cg.. Gentlemen: We ackiicvledrce receipt of yours of the twentyfirst enclosings copy of. your declaration to be filed in the Superior Court of Suffolk County in the above matter• Without tlxe files before ug wo can not ecy definitely the exact amount wliich sliould be Inserted In th© declara­ tion but 1X‘ the figures submitted in yojir lettei^ wex*© taken from the petition prepared by us we believe they are correct as w© had oonoldered th© imlter quit© Aurftriniv at that time* The telegram of February 4th quoted by. you in your letter was oonsldei’ed by th© interested parties as meaning? that Minty was guaranteed a minimum of $1,000*00 plus his expenses in tiio event that he was unable to earn more than $1,000.00 but that If his earnings exceed­ ed this amount ho was to pay fils own cravel expenses, such expenses la no event however, to include filing fees. Trusting that this sufficiently explains th© apparent Inconsistentty in the telegram, w© are Very truly yours, DORHAK & BACIUTLEIR e;b:s Air ?:all. �CHOATE, HALL & STEWART 30 STATE STREET JOHN L. HALL FREDERICK H.NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O. PENGRA CLAUDE R. BRANCH JAMES GARFIELD CHARLES P. CURTIS, JR. RICHARD C. CURTIS MARC1EN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT TELEPHONE HUBBARD 5020 CHARLES F. CHOATE, JR. 1899 - 1927 RALPH A,STEWART 1904 - 1926 BOSTON. MASS. Juoe 21, 1932 Messrs. Durham & Bacheller Casper, Wyoming re: Roy B. Minty v. Draper & Co., inc. Gentlemen: to enclosing herewith copy of declaration which I have prepared in the above action. As I do not have an itemized state­ ment of the account, I cannot be sure whether the figures'^alleffed ficrura-s nnAo-Ari are correct or not. I have taken them from your declaration and from such figures as I was able to find In the file. With refer­ ence to the sum of |6288.22, which Minty received, I am unable to r ‘'ST'-.? applied against the amounts which Minty disbursed for llllng The declaration declaration has has to to be be filed filed - fees, etc. The in court on T ? K there are any changes which should be made in it, I shall be obliged if you will let me know before that time. I not wholly clear as to just what the telegram dated February 4, 1930 means. The first part of it is as xwxxuwofollows: "Have following proposition to offer you from Draper & Co. stop You aM expenses on all wool you obtain stop Draper will guarantee you one thousand dollars plus expenses stop”. This language seems inconsistent to me. ;First it Thislanguage is stated that Minty is to 1/4 per pound less •; . . receive . '... ' of -- ----a cent expenses",* t-x^w. 44— stated that Draper will guarantee $1000 ”plus expenses”, J glad if you can enlighten me on this matter. . . , first part of the telegram means that there are certain loading expenses which are to be deducted from the com­ mission of 1/4 cent per pound, have these expenses been deducted? Very truly yours, ST V Enc. �CHOATE, HALL a STEWART 30 STATE STREET JOHN L. HAUL FREDERICK H.NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O. PENGRA CLAUDE R. BRANCH JAMES GARFIELD CHARLES P. CURTIS, JR. RICHARD C.CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT TELEPHONE HUBBARD 5020 CHARLES F. CHOATE. JR. 1899 - 1927 RALPH A.STEWART 1904 - 1926 BOSTON. MASS. June 7, 1932 Messrs. Durham & Bacheller Casper, Wyoming In re; Minty v. Draper Company Gentlemen: We note that you are agreeable that the case shall be tried before the court rather than a jury and we shall, therefore, waive claim for Jury trial. Of course, as I explained before. If the other side claim jury trial we cannot deprive them of a jury by waiving our claim for jury trial. With reference to the right to interrogate which exists in our Superior Court, but not in the Federal Court, that is a right to question a party on written interrogatories before trial. The answers must be made under oath and may be used by the party interrogating at the trial. Any matter may be covered by the interrogatories which Is relevant to the issues in the case. It Is in substance requiring a party to testify in advance of trial, but a party is limited to asking thirty questions. We shall forward you a copy of plaintiff’s declaration when the same has been filed. Very truly yours. SPT:EH �CHOATE, HALL a STEWART 30 STATE STREET JOHN L.HALL FREDERICK H.NASH JOSEPH WENTWORTH STUART C, RAND CHARLES O. PEN6RA CLAUDE R,BRANCH JAMES GARFIELD CHARLES P. CURTIS, JR. RICHARD C.CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT TELEPHONE HUBBARD 5020 CHARLES F, CHOATE. JR. 1699 — 1927 RALPH A.STEWART 1904 - 1926 BOSTON, MASS May 31, 1932 Dxxrham & Bach© Iler Casper, Wyoming Gentlemen; We acknowledge receipt of your letter of May 27, which apparently crossed ours of May 28We note that Mr. Tomason, who contracted with Mr, Minty by telegram, has died. We do not think this will make much difference to our case on© way or the other, because, under the laws of Massachusetts, statements of a deceased person may be admitted In evidence provided they wore made "in good faith before the commencement of the action and upon the personal knowledge of the Declarant*. Very truly yoxirs. ST V �May 51, 1932. Choate, Hall & Stewart Attorneys at Law 30 State Street Boston, Mass. Gentlemens We acknowledge receipt of yours of the 28th Inat. in the matter of Minty vs. Draper & Company, et al, and note that you have filed suit, and Uxat process is returnable the first Monday In July. We agree that this le a ease to be tried by the Court rather than a Jury, and If this oan be arranged we note that It will result In a speedier trial. Your docket must be oonsides^ably congested if it would take two years to bring the ease to trial before a Jury, Fortunately that condition does not exist in our local courts. We understand by the third paragraph of your letter, in which you state that If the case la removed to Federal Court you would be denied the right to interrogate, that you have reference to calling some member of Draper & Company to testify In advance of the trial. Please advise If we ara correct in this. Wo will be glad to receive a copy of defendant's answer and the Trustee's answer, and we would also like to have a copy of your Initial pleading for our files. Vex^ truly yours, DURHAM & BACHKhLKR, EPBsW �CHOATE, HALL a STEWART 30 STATE STREET JOHN L. HALL FREDERICK H.NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O-PENGRA CLAUDE R, BRANCH JAMES GARFIELD CHARLES P. CURTIS, JR. RICHARD C.CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT TELEPHONE HUBBARD 6020 CHARLES F. CHOATE. JR. 1699 - 1927 RALPH A.STEWART 190-4 - 1926 BOSTON, MASS. May 28, 1932 Messrs. Durham & Baoheller Casper, Wyoming Re: __ Roy B. Minty v. Draper & Company, Inc. and. The First National Bank of Boston, Trustee Gentlemen: We have obtained a financial report on the above defendant, have located their banking connection, and have brought suit of contract in the Superior Court for Suffolk County, return­ able the first Monday of July, In this action The First National Bank of Boston has been named as Trustee. The ad damnum of the writ is 17500. We will not know until the time for filing answers whether we have reached any funds by our attachment, but in view of the fact that our informant tells us the defendant carries a satisfactory account with The First National Bank, we assume that our attachment will be good. The last statement of Draper+Company, Inc., filed August 4, 1931, shows a surplus of ^801,235.68. In view of the diversity of citizenship of the plaintiff and the defendant, it would be possible to bring this suit in the Federal Court for the District of Massachusetts, where we would be able to gat a somewhat prompter trial than in the Suffolk Superior Court, where the docket is quite congested, and where It would be impossible to get a jury trial for in the neighborhood of 2 years. However, there are several disadvantages to trying In the Federal Court, among which is the absence of the right to interrogate, which we believe is important in this case. It would also be possible to get an early trial if this action were brought in the Municipal Court of the City of Boston. However, we do not believe it is advisable to try this type of case in the Municipal Court, which is in reality more or less of a police court where small matters are handled in rather summary fashion. �- 2 - Messrs. Durham & Bacheller May 28, 1932 We have requested trial by jury, but jury trial may be waived at any time, and if you agree with us, it would be our idea later to waive jury trial and ask for trial before a single justice. In view of the fact that the plaintiff is a non-resident of Massachusetts, we feel he would fare equally as well before a single justice as he would before a local jury. One advantage of trial before a single justice is that wo would be able to get a trial within a year. Of course, it is possible that the defendant may file a request for jury trial, and if it does so, then we cannot have a trial before a single justice. As you know, it Is also possible for the defendant to remove the action to the Federal Court but we do not regard this as likely. We shall forward you copy of defendant’s answer and Trustee’s answer as soon as they are filed. We will then want to take up with you the matter of deposition. Very truly yours. ST V �1932 Say Choate, Hall and Stewart 30 State Street Boston, Massaohusetts Minty vs. Draper & Co* RE| Gentlemen: We would appreolate It if you would advise us what progress has been made In this matter* Mr* Tom A, Tomason, referred to In the oorrespondenoe which we sent you, was recently killed In an automobile accident near Casper, and It would api>Gar to uo that hla death would materially weaken the defense of this action. He Is the gentleman sdio first contacted Mr. Minty by telegraph from Washington and, we understand, is the person with Wiior.1 Minty dlscuseed the 'matter later in Denver. Very truly yours, DTWAM & BACHELLER, ■ EPB:LO ■ •- " �CHOATE. HALL a STEWART 30 STATE STREET JOHN L, HALL FREDERICK H.NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O. PENGRA CLAUDE R. BRANCH JAMES GARFIELD CHARLES P. CURTIS, JR. RICHARD C.CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT TELEPHONE HUBBARD 5020 CHARLES F. CHOATE. JR, 1699 - 1927 RALPH A.STEWART 1904- 1920 BOSTON, MASS. April 28, 1922 B« Durham end. E. Paul Bachdllar, Esquires Casper, 'Jlfyomlng Attention of S. Paul Bacheller Centlemons Re: Roy B. Minty va. Draper & Company This la to aeknowledge reoelpt of your letter of April 20, 1922 enclosing your complete file In the above entitled matter. Aa soon as we have made a study of the file, we will communicate with you* Very tinily yours. ST <C �NOTE office'of CLERK UNITED ^KtES COURT RULE-COSTS OF CLERK DEPOSITS FOB SHALL BE MADE, AMD VHEM “Whenever sn action shall be brought or re­ moved into this court the plaintifT shall deposit with the Clerk, ten dollars, to be applied to the payment of costs as they shall accrue; in addition to the deposit of ten dollars, the plaintiff shall mve security tor all additional costs, to be approvea by the Clerk of this court, in the following form:— (Blank iormt oi bond furnished by Clerk) “The defendant upon entering his appearance, or filing any paper in the cause, shall deposit a like sum of ten dollars, to be applied in the same way; and in case of removal, the defendant shall in addition to the deposit of ten dollars, give se­ curity for all additional costs, to be approved by the Clerk of this Court, in the above form. “ Whenever the costs accruing against either party shall equal or exceed the sum so deposited, upon the demand of the Clerk, an additional sum 01 ten dollars shall be deposited by such party to be applied in the same way. In this way succes­ sive deposits of ten dollars each shall be made by each party as often as the first is exhausted.'* 1932 March 30 Oierk’s costs, NO. S1Q2.t(LLv11 CHEYENNE. WYO.,Maroh TiOth 191_? Poy B. ’'U nty‘j_ Plai nt i f f • Bv Durhan "^aoheller,attorneys To Charles J. Ohnhaus, Clerk, Dr. ........ . . . . . . . . $26.70 �EPARTMENT OF JUSTICE United States district Court OFFICE OF THE CLERK District of Wyoming CHEYENNE April 11, 1932. Durham & Bacheller, Attorneys at Law, Casper, Wyoming For Mr. Bacheller. Dear Mr. Bacheller: On March 30, 1932, wrote you enclosing bill for balance’of clerk’s costs due in civil case Ro. 2107, Roy B. Minty, Plaintiff, vs. Draper & Company, Inc., Defendant, amounting to $26.70. Up to this time had had no remittance and the Examiner from the Department of Justice is now checking my office, and it is necessary to account for this balance to the United States. Won’t you kindly give this your attention and let me have check promptly. Very truly yours. Clerk �April 1932. Mr. Charles J. Ohnhaus, Clerk United States District Court Cheyenne, Vi^oming Dear Mr. Ohnhaus: We acknowledge receipt of yours of the 21Bt In regard to coats In cases Mo. 2107 Civil, and No. 2158 Civil. We have delayed remitting these costs because Mr. Minty has been out of town, and onlyreturned today. We ni'e enclosing herewith our check to your order In the anount of 026.70 covering the costs In No. 2107 Civil, and check to your order in the ainount of $24.75 In No. 2158 Civil. We are sorry that there was delay In remitting these costs. Vei*y truly yours, DOKHAM & BACHELLER, EPBtW Knc.2 �Department of Justice United states district court OFFICE OF THE CLERK DISTRICT OF WYOMING CHEYENNE April 21, 1932. E. Paul Bacheller, Esquire, Attorney at Law, Casper, Wyoming. Bear Paul: Am sorry, but again must call your atten­ tion to the balapce of clerk’s costs due in the following cases: Ho. 2107 Civil, Roy B. Minty, vs. Draper & Company, Inc., $26.70; No. 2158 Civil, Annie Shikany, vs. The Missouri State Life Insurance Company,........................... $24.75. Sent notices to you of these costs on March 30th and April 11th. The Examiner from the Department of Justice is at this time checking this office and will require me to advance these balances from my own pocket unless you can obtain remittances for me. Please get me checks as soon as you can, and oblige Very truly yours. KHP �—•> Rec^i for Article No. Resiatered at the Peat Office Indicated in Poataaarb Fee paii_____ ____ etnis Cla^^^siage _ ___ J.__ Return Receipt fee.— Delivery restricted to addressee: In person or order )i.. 47'.— Accepting employee will place his.- intltote In siace Indicating restricted delivery. §5:;.- POSTMASTER, per.. The seoder should write the name of the addressee on backhereofaaaoidgntification. Preaerre nod submit this receipt in case of inquiry or application forindcnnity. Registry Fees and Indemnity.—Dome^m.registry less caige from 15 cento forindeonity not exceeding 850 up to 81 for indemnity not esifteding 31,000. Th, fee on demestic registered matter without intrinsic value and for which indemnity is not paid is IS^cots. Consult noatmaster as to the specific domestic registry fees and as to the regetry fees cbargeabi, on registered parcel-post packages for foreign countries. Pees on domeatio registered C. O. D. nail range from 25 cents to 81.30 Indemnity claims must be filed within one year (C. O. D. eizmonhs) faom .n.ii.-ng, Form 380$ (IUv.7-1-29) c5—0862 i. a corwiaaKipuktbc omoe; uia April 20, 19320 Choate, Hall & Stewart 30 State Street Boston, Moss Gentlemen: Supplementing our letter of the 19th, and so that you may have a clearer picture of the situation, Thomson, referred to In the oorrespondenoe, cam© to Wyoming oom© time after meeting Minty in Denver, and proposed to Minty that they pool the wool purchased by each and split th© coTrsnlsslon. Thomson, however, wanted to reserve to himself th© territory In southern V/yomlng along th© Union Pacific line, and this Minty would not agree to. Tonnage obtained along the Union Pacific usually ran quit© high, and if Thomson had been willing to Include this Minty would have accepted, and It would have meant that Minty’s commissions would have probably been increased at least ^1,000.00, but when Thomsen wanted to receive all of th© commission for the Union Pacific business and split with Minty on the balance of th© territory, he promptly refused. Minty has kept very accurate records, and can establish each person from whom he purchased wool and th© amount of each purchase. W© do not know how familiar you may be with sheep and wool business, hut it Is customary for the commission men to purchase the wool prior to shearing and advance to th© grower a certain percentage of the appraised value of th© wool. These ar© the pre­ shearing advances referred to in the correspondence. Later, wh©n the wool is clipped and shipped, th© balance is pa 1. Very truly yours. DURHAM & BAOHBZXSR, BPBtW �April 19, 1932. Choate, Hall & Stewart Attorneys at law 30 State Street Boston, Macsachusette Gentlemen: acknowledge reeelpt of yours of the 16th, in the matter of Minty vs. T^raper c*: Corrpnny. VZe have thought it best to forward our entire comes* pondence file, and while there Is a good deal of the correspond­ ence which will doubtless be of little. If any, value, it neverthe­ less may nsslet you In showinc the close relationship which existed between Minty and reaper & Company during the period of employment. You will note a letter under date of August 19, 1930 signed by J. C. Wilson, written on stationery from the Sheinnan Hotel, Chicago. He Is the person referred to In correspondence as "Byron Wilson*', and is manager of the National v/ool Cooperative Marketing Association, and offices with Draper & Company In Boston, at 281 Summer Street. The contract between Draper £c Company and the National Wool Cooperative Marketing Association was executed by J. B. Wilson, and provides that It relmbiu^ses Draper Sc Company for all corvrisslons nald by Draper Sc Company for securing wool to be marketed through the National Asnoclatlon. The original telegram, dated February 4, 1930, signed G. T. Thomson", Is the telegram Initiating the employment, and its terms v/oro later confirmed at tlio meeting held"between Thomson and Minty In the I3rown Palace Hotel, Denver, Colorado. Thomson Is cn officer of Draper & Company. This matter was originally referred to the firm of■ Nichols & Ptirrett of this city, and we a?’e enclocln" the corres­ pondence between T'jraper Sc Compejaj and that firm, as we handle all trial matters for the firm of Nichols & Stlrrett. * When it became evident that cult v.*ould be necessary the file was referred to this office. You \7ill note a letter from Draper Company to Nichols & Stirrett ’uider date of November 29, 1930, which refers to the original telegram sent from '-’ashlngton by Mr. Thomson. When you have had an opportunity of reviewing this correspondence we v/111 be represent you in the taking of 1&*. Minty’s deposition here. V-^e presume the original telegrams should be attached to his deposition. Mr. Carl P, Shumaker, Vlce-Pi'csldont and Cashier of The T^Offilng National Bank of Casper, can testify, if you think It necessary, as to Minty drawing drafts on Draper & Company from time to time, which drafts were by It paid. At that time The Wyoming National Bank had an assignment of commissions under �Page 2. To Choate, ^al3. & gtiBwart Minty’s contract, a copy of which Is In the flies enclosed herevdth, but leter the contract was re-assigned to Minty. ;.o noL& that you will handle .this matter for us on a contingent basis of 20^of the gross amount received, plus refund of expense incurred» If you will bill us for the expense as It Is Incurred we will be glad to remit our check covering. Very tjmly yours, DURHAM & BACHEIiKR, ny9 ; EPBxW �WM- CHOATE, HALL & STEWART 30 STATE STREET JOHN L. HALL FREDERICK H.NASH JOSEPH WENTWORTH STUART C. RAND CHARLES O, PENGRA CLAUDE R. BRANCH JAMES GARFIELD CHARLES P. CURTIS, JR. RICHARD C.CURTIS MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT TELEPHONE HUBBARD 5020 CHARLES F. CHOATE, JR. 1899 - 1927 RALPH A.STEWART 190.4- 1928 BOSTON, MASS. April 16, 1932. E. Paul Bacheller, Esquire, Casper, Wyoming. Dear Sir: We have your letter of April 12 concerning the claim of Roy Minty v. Draper & Co., Inc. As we understand the situation from your letter with its enclosure, it would he necessary for us to start suit prohahly in our Superior Court. We would expect to undertake to trustee the bank account or bank accounts of Draper & Co. in order to be sure to have funds available in case of obtaining judgment and also to put pressure upon them to expedite the suit, or even to settle it without trial. We would probably then interrogate the defendants under our practice before taking the deposition of Mr. Minty in Wyoming. Mr. Minty’s deposition would then be taken and we would hope to persuade the court that it ought to be taken on oral examination rather than on written interrogatories. When the case comes to trial, the most important element will, presumably, be the cross exam­ ination of Mr. Bennett and perhaps other officers or employees of Draper & Go. The out-of-pocket expenses Involved in the proceeding as outlined above, other than those connected with the taking of the deposition in Wyoming, should not amount to more than perhaps $20 « $25., Including the financial investigation necessary to locate the bank accounts of Draper & Co. �E. Paul Bacheller, Esquire April 16, 1952 - 2 - In view of the circumstances as we now under­ stand them and of the fact that the primary responsibility for the handling of the case, and particularly the cross examination of the defendants* employees, will fall upon us, we are willing to handle the case for you on a contin­ gent basis of 20% of the gross recovery to us. We would also expect to be reimbursed for our actual out-of-pocket expenses which, as stated above, would be a very small it em. This proposal is based on the assumption that the cost of taking the deposition in Wyoming, Including yoxir fees for that service, will come out of your portion of the total fee. If you desire to have us proceed on this basis, we will be glad to receive the correspondence and telegrams passing between Minty and Draper & Co. or its representatives Very ti*uly yours, JG:MEM �March Zl, 1932 Mr. Charles J. Ohnhauc, Clerk United States District Court Cheyenne, ’jVyomlns Door Mr. Ohnhaus: aoknowledce reoelpt of yours of the 30th, enclosing; copy of Judge’s memorandwn In the natter of Minty vs. Draper Sc C<»npany, together with statement for Clerk’s costs. We called Mr, Minty, and find that he Is out of the city, but la expected to return tomorrow. Immediately upon hie return v/e will procure the costs from him and forward them. Very truly yours, DUKHAM & aAGHELX.Sn, DP 1 S^BtV �Department of Justice United States District court OFFICE OF THE CLERK District of Wyoming CHEYENNE March 30, 1932. Durham & Baoheller, Attorneys at Law, Mitdwest Building, Gasper, Wyoming. For: Mr. i£. Paul Baoheller. Dear Mr. Baoheller: For your- information, am handing you here­ with oarbon copy of Judge’s Memorandum this day filed in civil case No. 2107, Boy B. Minty, Plaintiff, vs. Draper £c Company, Inc., a corporation, Defendant. An Order sustaining the motion to quash and dismissing the case at plaintiff’s cost, with exception to plain­ tiff, was today entered in this case. Pursuant to the Order of dismissal have taxed the Jlerk’s costs and find there is a balance due amount­ ing to $26.70. As I am required under the law to account to the United otates for these fees, as of the date the, dismissal is entered, will appreciate prompt remittance. As you may desire to take the matter of costs up with your client, am enclosing bill for your conven­ ience. If there is anything further I can do in oonnection with this case, please advise me. MF Snc-S �April 12, 1932. Choate, Hall & Stewart Attorneys at Law 30 State Street Boston, Massachusetts Gentlemen: We acknowledge receipt of yours of the 9th, and accord’n^ly submit for your consideration claim of Roy S. Minty vs. Draper & Company, Inc. Following the enactment by Congress of the so-called National Marketing Act" there was organised the National Wool­ growers’ Cooperative Marketing Association. There was likewise organized the \'^omlng Wool Cooperative Marketing Association. Draper fr. Company was selected by the National Association to market the wool purchased by It ?n the various wool growing states. Including Wyoming. To encourage growers In the various states to market their wool through the local cooperative marketing association, and thus through the National Association, Draper & Company employed agents and paid them a commission based upon the tonnage they were able to procure in the various states. The plaintiff was employed on the 4th of February, 1930 to represent Draper & Company In i^omlng, and It was agreed that ho was to reoelve per pound for all wool he could purchase. He was able to contract for 4,092,673 pounds, which entitled him to a commission of $11,731.68. Of this amount he was paid $6,288.22, leaving a balance of $5,893,46, vftiloh he claims with interest at 7% per annum (being the Womlng statutory rate) from the 11th dav of August, 1930. Minty was employed by telegram from one H. H, Bonnett, an employee of Draper & Company, and later Bennett come to Wyoming. He claims that after arriving in VZyomlng the terms of Mine's employment were changed, so that Minty was to receive per pound, instead of and Bennett was to receive the other 1/8^ per pound as a sort of overriding royalty. The contract was a written contract, entered into by telegram, and we dispute any alteration of the original terms of the contract. V/e are enclosing copy of a petition -d'lch wo nropared some time ago for service upon rnper Company, but because they were not technically doing business in V.yomlng we could not get a valid service, and find It necessary to Institute suit at Boston, This petition will give you such data as would be necessary in preparing suit. V/e will probably have to rely upon the deposition of Mr. Minty, which can be token here at any timer �If you want th© correspondence and telegrams passing between Minty and Bennett, and Minty and Draper & Company, we will be glad to forward them. After you have had an opportunity of considering this matter w© will be glad to have you advise us on what net percentage to you the suit will be handled. /Very truly yours, DURHAM & BACHELLER, EPB:W �CHOATE, HALL a STEWART 30 STATE STREET CHARLES F. CHOATE. JR. JOHNL HALL FREDERICK H.NASH FRANK W KNOWLTON JOSEPH WENTWORTH STUART C. RAND CHARLES O.PENGRA JAMES GARFIELD MARCIEN JENCKES ROBERT PROCTOR MAXWELL E. FOSTER RICHARD WAIT 1899 - 1927 TELEPHONE HUBBARD 5020 RALPH A. STEWART 1904 - 1928 BOSTON, MASS. April 9, 1932. Durham & Bachellor, Caspar, Wyoming. Gentlemen:We have your letter of April 5th Inquiring whether we are in a position to handle a claim against Draper & Company on a contingent basis. We would be glad to handle the claim on such a basis, provided we can agree on the details. Very truly yours, ja/j CXar -< �Department United states of Justice District Court OFFICE OF THE CLERK District or Wyoming CHEYENNE January 14, 1932. E. Paul Bacheller, Esquire, Attorney at Law, 402 Hid west Building, Casper, Wyoming. Dear Sir: My deputy advises that you desire me to drop you a note at Casper concerning docket fee which is due from plaintiff in our civil case No. 2107, Roy B. Minty, Plaintiff, vs. Draper Sc Corrpany, Inc., Defendant, in which you filed your appearance on January 13, 1932. If you will let me have check for this docket fee, will greatly appreciate it. Very trul^ yours, er k. KHP �April 5, 1932. Choate, Hall & Stewart Attorneys at Law 30 Stat© Street Boston, Massachusetts Gentlemen: V/e have a claim a?’alnst Draper & Company, wool commission merchants of your city, Involving approximately ('6,000.00, Growing out of the breach of a contract of employment In V/yomlng during the year 1930. It will be neceseory to handle the litigation on a contingent fee basis. Vito have had some contact with Draper & Comptiny, and feel satloflod that If suit Is filed a settlement Qon be obtained. V/111 you please advise if you are in a position to handle this Item for us, and if so wo will “Ivo you a oor^loto history, following which you may advise us upon vjhat basis you will handle the sul t for us. (7e take your name from The American ISar. Very tzmly yours, DURHAM & B&CHELLBR, By EP3:r? �Department of Justice United States District Court OFFICE OF THE CLERK District op Wyoming CHEYENNE March 1, 1952» Durham & Bacheller, iLttorneys at Law, Midwest Building, Gasper, Wyoming For: Mr. S. Paul Bacheller Dear Sir: x*ctaiowled.-?e receipt of your letter dated February 29th, enclosing Plaintiff’s Brief in civil oase No 2107, Hoy B. Minty, Plaintiff, vs. Draper & Gompajiy, Defendant. This Brief has been filed to- day and will be presented to the Court, to?rether with the balance of the record, upon his return to Cheyenne �Pebzniary 20, 1032. Mr. Charles Ohxdiaus Clerk U. 3. Plstrlot Coiirt Cheyenne, T^omlng Dear Sirs We enclose herewith for filing Plaintiff’s I3rief in the inatter of P-oy B. Minty vs. iraper Ss Oomparcy, Civil 2107. Very truly yours, DURHAM & BACHEIXER, �Pehruary 29^ 1952 Mr* K. A. Kline Attorney at Law 507-511 Majestic Bldg. Qieyenne, V«yoming Dear Sir: We enclose herewith copy of Plaintiff’s Brief in the Case of Minty vs* rE*ap©r & Conpany. Very truly yours, IXJHHAM ft BACBSLLBH, �February 1938 A* Klino at Law 507«511 liajostlc Dltig* Cheyonzw^ Mr. Lear Sirs We ackno-’led^e 3?eoelpt yours of the 3rd enclosing copy of your brief In the Case of Klnty vs. Draper & Conpeny. We will fon/ord you copy of our brief as soon as It la prepared. Very truly yours, DUFHAIS k BACUE1X£K, EPBiW �M . A . KLIN E ATTORNEY AT UAW 507-511 MAJESTIC BUILDING CHEYENNE, WYOMING February 3, 1932 Messrs. Durham & Bacheller Attorneys-at-Law •Casper, Vfyoming Gentlemen:— I am enc losing herewith copy of brief of de­ fendant on the motion to quash in the case of Roy B. i.-Iinty, plaintiff, vs. Draper & Company, Inc., defendant, which I am filing today in the United States District Court. Very respectiiilly yours, * LUK: EG Enclosure » �Department of Justice UNITED STATES DISTRICT COURT OFFICE OF THE CLERK District of Wyoming CHEYENNE January 2b, 19 32. Durham & Bacheller, Attorneys at Law, Casper, Wyoming. * Centlanen: Acknowledge receipt of your letter dated January 23, 1932, enclosing affidavit of Roy B. Minty wtiich was this day filed in civil case No. 2107, Roy B. Minty, Plaintiff, vs. Draper & Coii5)any, Inc., Defendant, and the copy has been forwarded to Mr. Kline. Very truly yours. KHP �M. A. KLINE ATTORNEY AT LAW 507-5(1 MAJESTIC BUILDINC CHEYENNE, WYOMING January 23, 1932 Messrs. Durham & Bacheller Attorneys-at-Law Casper, Wyoming Gentlemen:— In accordance with the order of the Court in the case of Roy B. Minty Ts. Draper & Company, I am enclosing herewith copies of the affidavits which I am today filing in the above matter. I think you have copies of the affidavits of Joseph P. Draper, George W. Brown and Paul Draper which were filed prior to the first hearing in the above matter. If you do not have copies of such affidavits, please notify me and I will have copies made and send them to you* I am enclosing herewith copies of the affidavits of Charles I. Tuttle, Charles M. Wilson, W. 0. Carleton, and a new affidavit of Paul Draper. I have been waiting to get other affidavits which were supposed to have been sent, but which seem to have either been lost in the mail or sidetracked. I may get them later on so as to be able to file and serve them on Monday. If not, I will submit the case on these affidavits, together with the affidavits of Joseph P. Draper and George W. Brown which were filed at the time we filed the motion to quash. Very respectfully 3rours, MAK:EG Enclosures �January 23, 1932 Mr* Charles J* OhiihauB, Clerk XTblted States Dlstriot Court Cheyenne, Vyowlng Dear Sirs We enclose herewith for filing affidavit of Hoy 5. Minty, In the matter of MXMTZ'vs. & COMPAITZ, XMC*, Civil 330. 2107. Very truly yours, DURHAM & BACHELI^R, By EPBsW �January 22, 1932 Clerk of XJ.S.Dlat.Court, Cheyenne, Wyoming# Dear Sir: As per instructions from Kr- E. Paul Bachellor, I am enclosing herewith affidavit executed by myself. In connectlcffi with the case of R.B. Minty versus Draper and Company, Inc#, Civil Case #2107. Yours very truly. Encl �Department of Justice United States District Court OFFICE OF THE CLERK District op Wyomino CHEYENNE January 16, 1932. Durhaui & Bacheller, Attorneys at Law, Kid west Building, Casper, Wyoming. For Mr. Bacheller. Dear Sir: For your information, beg to advise you that on Friday, January 15th, the Court entered an order in civil case No. 2107, Roy B. Kinty, Plain­ tiff, vs. Draper 5c Company, Inc., Defendant, as follows: At request of counsel, motion to quash service submitted to the Court on affidavits and briefs, each side allowed to and including January 25, 1932, to file any additional affidavits and serve on counsel. Defendant ten days from January 25, 1932, for briefs and service on counsel, and plaintiff ten days thereafter for brief and service on counsel. Very truly yours, KHP �LAW OFFICES OF Maurer & Maurer First Stale Bank Bldg. Douglas,Wyo. CHARLES F. MAURER DKOSABKB RICHARO C. MAURER J A H n A R T ELEVENTH 19 5 2 Mr. Roy Minty Henning Hotel Casper, V^omlng Dear Mr. Minty: Regarding the affidavits which this office prepared for the signatures of Jack Mortal, Charlie Saul and Mike ^illiams, these were prepared but it will be impossible to get Mr. Sauls signature on his until tomorrow evening about 5:30 P.M., at which time he is supposed to be in from his ranch. He will have these duly signed up and wiU. mall them to Cheyenne, in care of the Plains Hotel so that you will receive them Wednesday morning. Tours very truly. MAURER & MAURER N M C s �H I UU & ATTORNEYS AND H I L.l_ COUNSEUOR* AY LAW BUrrALO, WYOMING T. R. HILU ■URTON •. HILI. January 9, 1931 E. Paul Baoheller Durham S: Bacheller, Attorneys Consolidated Royalties Bldg. Casper, YVyoming Dear Mr. Bacheller: Mr. Roy Minty wanted me to secure from Fred W, Hesse an affidavit to the effect that James Hannon was solliciting for Draper Company, Inc., of Boston, Llassaohusetts during the shearing season of 1931. I have just talked to Kir. Hesse and asked him for such an a ffidavit, and he informs me that it is his belief that Draper Company were in some manner or other absorbed by what he termed the National 'Jool Growers Cooperat­ ive Association, located in Boston. I do not know ex­ actly what this means, except that perhaps the Cooper­ ative Association in some manner or other took Draper & Company over; but I am sure you will know what the situation is, Ur. Hesse informs me that our Coiinty Agent, Mr. D. A. Jay, address, Buffalo, Wyoming, could probably give you all the particulars; I would therefore advise you to drop him a line. With kindest personal regards to you and Harry, I am Most sincerely yours Burton S. Hill BSH:HA �WlIiFHID O'LeABY Counselor at Law Che ye xxe , Wyom ing January 8, 1932 Harold Bacheiler, Esq.. Attorney at Law, Casper, '»VyoBiing ’ ^i^ty vs. Draper & Co. Inc, Dear Mr. Bacheiler: I prepared and served on Mr. Kline today, notice of intent to take depositions in the above case. Mr. Kline did not want to admit service of this notice and he explained to me that his reason was because of the fact that he was appearing specially in this matter, and was e/raid that such admission of service mght be construed as a general appearance. 1, therefor, have made affidavit of service and am enclosing you herevzith the notice, together with a copy thereof. zoYours truly, WO»L:LW / ) �OFFICE OFF LOBBY HENNING HOTEL ROY B. MINTY GENERAL COMMISSION WOOL,SHEEP AND CATTLE CAS PER, WYOMING August 22, 1931 Durham and Bachelor, Attorneys, Con-Roy Building, Casper, Wyoming. Attention Mr. E.Paul Bachelor Dear Mr. Bachelor: Will you please, at your early convenience, write me a letter stating the terms of oir agree­ ment with reference to your handling of the Draper lawsuit? As per our conversation in your office at the time this matter was first discussed, you ad­ vised that, to avoid misunderstanding, you would write such a letter and I am directing your atten­ tion to it, believing It has probably slipped your mind. Referring to the Haley matter at Wprland. as vou probably will remember, we were waiting for ?p^?tunlty\o serve Kr Haley in Casper. I an advised that at the present time he is in the Platte Valley and expecting to return the first of the week. What do you think about preparing the papers and hay­ ing them’ready in the event he stops in Casper on his return to Worland? Yours very truly, 6^ R B K * P B �a OFFICE OFF LOBBY HENNING HOTEL ROV B. MINTY GENERAL COMMISSION WOOU.SHEEP ANO CATTL.E CASPER, WYOMING Denver, Colorado,Decemberl9,1931 Meesrs. Durham & Baohellor, Casper, Wyoming. Gentlemen: Whether or not the information herewith is of any value in our case with Draper & Company, is of course, for you to decide. , In 1930 when H.H • Bennett arrived in Casper from Boston, representing said Draper & Company, about the first thing he did was to begin managing for an automobile. After securing prices, etc., he sub­ mitted his proposition to Draper & Company in Boston, and later they authof^ized him to purchase automobile. Immediately on being authorized to make this purchase he bougjit a oar from the Earl Boyle Company. Whether or not the Bill of Sale was made to H.H. Bennett or to Draper & Company, I cannot say. Who the lloense was issued to, I do not know. However, I do know this positively, that when Bennett presented draft to the Wyoming Trust Company for the amount necessary on Draper & Company, Mr. D unn of the Wyoming Trust would not give Bennett the money until the draft was cleared. Bennett was very much annoyed at the attitude of the Bank and left their office in a "huff" and went over to the Wyoming National Bank where he received the money immediately, and went back to the Ford office and paid for his car. When the wool buying season was over according to agreement with the Ford Company he turned the car back at a value fixed at the time of purchase. Now, later. In 1931 the same procedure was follow­ ed, except that in purchasing a oar in 1931 he made a very similar deal with the Chevrolet Company receiving the oar at the beginning of the wool buying season and turning it in at the time he returned to Boston. �-2- Anotho' point which might be well to invewtigate is who the Policy on this car was issued to* I do not remember with whom he took this Policy in 1930, but in 1931 the Bon Company wrote the policy* I remember this instance about the Insurance particularly, because of Bennett’s conversation with reference to his firm's liability in case of accident, whom he was most anxious to protect. If the above is of any metfit I believe you will ha'be no trouble whatever in confirming the same from records in Casper. I am leaving today for Oakley and if you wish to advise me with reference to this or any other matter, you will find me there. Yours very truly. �1206 A WesterI^ LUi-jJ iw SERVICE DESIRED' DOMESTIC CABLE TELEGRAM FULL RATE DAY LETTER DEFERRED NIGHT MESSAGE NIGHT LETTER CABLE LETTER UNION WEEK END LETTER Patrons Bbould obeck class of service desired; otherwise messase will be transmitted as a (ull-rate \communication. f NEWCOMB CARLTON. RReeiDBNT J. C. WILLEVER. FIRST VieB-FRMIIbBNT Said the following message, subject io the terms on hack hereof, which are hereby agreed to Deoamber 10, 1051 Hoy B. Minty Oakley, Kansas Hearlnrr Draper and Company Choyenne slxteonth. (Stop) No settlement made. IXJHUAS ^6 BAGHKZiLKR. (C0LI£CT) THE QUICKEST, SUREST AND SAFEST WAY TO SEND MONEY IS BY TELEGRAPH OR CABLE �li lt TO FAVOR THE COMPANY BY CRITICISM AND SUGGESTION CONCERNING ITS SERVICE ftill-rate or Cable-.iii unless its de­ terred character is in­ dicated by a suitable sign above or preced­ ing the address. STERK UNION NEWCOMB CARLTON. PRI.IOINT laol-S SIGNS DL = Day Letter NM = Night Message NL "» Night Letter Leo a Deferred Cable CLT =» Cable Letter WLT - Week-End Letter J. C. WILLEVCR. riR«T VICB.RMSIOBNT The tiling time aa shown in the dateline on tuU-rate telegrama andday letters, and the time of neeipt at datiaattoa'M^bOTra'ra'airmwi^esTisSTAKDARD^lMEr' Received at 138 North Center St., Casper, Wyo. VAlb l93lOEe tO AM 7 26 NL=OAKLEY KANS DURHAM AND BACHELLOR= CASPER WYO=^ PLEASE ADVISE IF POSSIBLE WHAT ACTION DRAPER AND CO WILL TAKE STOP IF WE ARE GOING TO BAT DEC SIXTEENTH I WILL REQUIRE TIME TO RETURN TO CASPER FOR ONE DAY BEFORE THAT TIME WHICH _ WILL NECESSITATE LEAVING HERE THIS LEEKEND= RAY B Ml NTH THE QUICKEST, SUREST AND SAFEST WAY TO SEND MONEY IS BY TELEGRAPH OR CABLE L �Department of Justice United States District court OFFICE OF THE CLERK District op Wyoming CHEYENNE November 9, 1931 Durham 5c Baoheller, Attorneys at Law, Gasper, ^Tyoming* For: Mr. E. Paul Baoheller. Dear Sir: For your information, beg to advise you that the Court this day entered an order in Civil case No. 2107, Boy B. Minty, Plaintiff, vs. Draper Sc Company, Inc., a corporation, Defendant, setting the hearing on motion to quash at Cheyenne, December 16, 1931, at ten o’clock in the forenoon. Very truly yours, MF �M. A . KLIN E ATTORNEY AT LAW 507-511 MAJESTIC BUILDING CHEYENNE, WYOMING June 24, 1931 Durham & Bacheller Attorneys-at-Law Casper, Wyoming Gentlemen: — In Re: Boy Minty vs. Draper & Co«, Inc, I am enclosing herewith copy of special appear­ ance and motion to quash and copies of the affidavits filed in support thereof which I am filing this day in the office of the Clerk of the United States Dis­ trict Court here at Cheyenne, I am sorry for the delay in this matter, but it has been occasioned by the fact that I was not able to locate Mr. Paul A. Draper and get his affidavit before Monday of this week. I mailed him two or three letters, but it seemed each time that I just missed him. Very respectfully yours. MAK: EG Enclosures �■-■-'J TH Tffl ilm® . FO9 MB XKUTRICt OF WTOMIW Civil Fo. 2107 ROT D. mm Plaintiff. * WUPKR & CO»PA»r, IBO.^ a CorporatlOBi ' «*>>' '■' - •*• \ ' '*-• * *'«<!.• ■^‘'''' *?> '-M' '■' gmgy OF PUiygiyy Ab noted In Uxe brief of the defendant thia aotlon traa begun In the District Court of the Slghth Judlolal Dla- :';//t^'ot against the above nased defendant to reeover a »oney Judgment Tor a balance claimed to be due the plaintiff for oonmlaalone earned by him while a representative of the defendant corporation In the State of >Vyo®lng during the year 1930. At the time of filing Its Petition for Removal the defendant filed a special appearance seeking to quash servloe of suaiBons made upon It In Fatrona County, l^yonlng, upon the ground that It vas a foreign corporation not transacting business In the State of Wyoming. Evidence was introduced In opposition to defend­ ant’s Motion to Quash, and thereafter the matter was continued f«f» the sut®lsalon of further evidence either by the way of affidavits, depositions, or oral testimony. The Court being unable to take further oral testimony, the matter now stands upon the testimony introduoed by the plaintiff and defendant at the original hearing and affldavltB subsequently filed. At the original hearing the plaintiff testified In his own behalf that he was employed by Draper & Company, ths defendant, �to jnirchase wol f(»* It In the State of WyoMng during the year X9S0, and «ae te he paid a eoBBslsalon upon the poundage eecured hln ^dr the defendant* *nie teatlnony for the plaintiff, la edition, shoved that he eollelted manor wool grovera and proeured for Draper k C«Bpany, daring the year 1080, a large qxxantlty of wool, that he oalatalned an office In the City of Caaper, and, vlth the knowledge and oonaeat of the defendant, displayed upon the glass entrance thereto. In large letters, the name of the defend­ ant, and plaintiff's name as local representative* Be likewise advertised In other ways, with the knowledge and consent of the defendant, his representation of them* Through the procurement of the defendant he was appointed an assistant secretary of the Ironing Woolgrowers Cooperative Marketing Association, and was authorised to draw drafts not only upon the National VooXgrovers Cooperative Marketing Association, hut upon Draper & Company as well, and the forms of draft used by him were Introduced In evidence at the original hearing. Zt would seen that, subsequent to the time Ihraper & Company originally started to do business in v^omlng, the method of operation was changed, this due to the enactment by Congress of what Is popularly known as the "Rational Marketing Act* (7 V.S.C.A. et seq*), itoioh, sxonnarlzed, provides for the marketing through nationally organised corporations of various products. Including wool, through national cooperative marketing associations. In pursuance of this Aet there was organized the National Wool­ growers' Cooperative Marketing Association. Local cooperative marketing associations were authorised to market wool through the Mtlonal Association, and with Its facilities, but this advantage. If It can be so designated, was denied Individuals. This aeoounts for the organisation of the Wyoming Woolgrowers Cooperative Marketing Association, and by marketing wool through the latter �organisation, automat!oally made it a member of the National Aaeoolatlon. In order to become a member of the local organisation : It la only necessary that local voolgrovere market their wool . throu^ the local cooperative asBoolation» Draper Coi^mny, its following the organisation of the National Aeeooiatlon* exclusive sales agents. We ^wn have this altuatlcms A local woolgrower beeomes a member of the local cooperative association by marketing hie wool through the local association, understanding and knowing that It will be sold eventually by Draper & Company as exclusive sales agents for the National Woolgrowers Cooperative Marketing Associa­ tion. In order, then, to Inorease tonnage to be handled by the defendant company they send in to the various territories, during the wool-buying season, their representatives to encourage local growers to market their wool through the local cooperative associa­ tion, thus through the National Association, and finally through Draper & Company. Drafts for advances are drawn upon the National Association, and the advance is repaid iftxen the wool is ultimately sold by Draper & Company, so that, instead of buying and selling direct, as had theretofore been the custom. Draper A Company indirectly, throxigh the local and national associations, buy for the purpose of re-sale by them either on a stated commisalon or salary. In any event, it is the tonnage they are able to acquire from the different localities which determines the voltsse of busi­ ness to be done by them during any given season* The mere fact, if it be a fact, that the defendant \ " M i;" eox*poration failed to eoBg>ly with the foreign corporation laws of the State of wyomin;::, can be of little, if any, significance in determining whether they were doing business in W>omlag* If all foreign corporations complied with the corporate laws of tibe various states the question of when they were or were not doing �business would no ver arise, so that. In thio case, the affidavit of the Deputy Secretary of state can scarcely be of benefit la determining the status of Draper & Company in Wyoming during the year 1931 * The plaintiff testified that during the year 1931 Paul Draper, President of the defendant corporation, and a person upon whom service of sunsaons may be made (W.C.S. 1920, Seo. 5631) was in Wyoming, addressed various conventions, and was here for the purpose of promoting the business with which he was connected. It was while he was here transacting business for his company that he was sez>ved with process. There is no doubt but that Draper was in Wyoming, and there la no doubt that, while he was here, he was so served. Counsel say in their brief that his visit to Wyeadlng was for purely personal reasons, and upon the Invitation of the Wyoming Woolgrowers’ Cooperative Marketing Association. This Is scarcely justified by the evidence, and even the statement of counsel shows that his presence in i^omlng, even If upon the invitation of the Wyoming Vfoolgrowers’ Cooperative Marketing Association, was, nevertheless. In connection with the business of Draper & Company, as wool merchants, because he attended a conven­ tion of wool growers sftiich was then in session at Oasper, and for the purpose of explaining to them "the advantages to be derived from the cooperative system of marketing their wool through the Watloxial Wool Marketing Corporation*. Certain It Is that during 1931 Draper & Company had representatives in Wyomlns, how many we do not know. Ki a sick was one, and H. H. Bennett another. William J. Mr. Bennett had sufficient authority so that he was authorized to and did draw ■ drafts upon Draper a Company, his employer, and for aught that appears the drafts were all honored. Counsel cites Section 6S33 W.O.S. 1980 as being an exclusive method of service of subsbcab upon a foreign corporation. �and eltea, In support, certain deolaion.of nisi prlus courts of Ohio. ’.VyoBilng has apparently never passed x^cm thia aeetlon of the statute, but It would appear to us that the statute aentloned Is not controlling. Ooaeelvahly a foreign corporation night have many esqployees in a given state with no managing agent phya 1 eally present, Sven so, the statute Is penal sal vs by Its terns only, and aay st **Whea the defendant la a forelm oorporatlon having a managing agent In toLs state the servlee wr be upon suena^nt. -.-r-r^T^rrr-r At pointed out In Beach v. £err Turbine Company, 843 Fed* 70d, the ob^eot of these statutes Is to give a corporation notlee of the pendeney of an action. It Is seen by 5631 supra that service may be made upon the President, and It would certainly seem to us that service upon the chief officer of a corporation would be the most effective method of bringing to the attention of the corporation the fact of the pendency of an action* As said In Beach v. Kerr Turbine Company, supra, ”The question Involved in this action, however- seems to me to be different and is controlled by other considerations. It does not follow that statutes fixing the conditions under which a foreign corporation may engage in business In a state are to have the same , construction as statutes permitting a foreign corpora4 tlon to be served In a state where it may be foimd. In the former It Is, ofeourae, a more or less continuing - course of business, which Is meant to be regulated, whereas, In tho latter, the object sought la only to give notice to a corporation of a pending action* Ihe tendency is to hold that whatever is reasonably effective for this purpose Is a good service.® In the last case cited, the case of Conneotloutt Mutual Life Insurance Company v. Spratley, 172 U.S. 602, 19 S. Crt. 300, 43 L. Ed, 560, digested, It Is saldt ”ln Connectloutt Klutual Life Insurance Company v. Spratley the Insurance company had been doing business In Tennessee, and afterwards withdrew all Its agents from tho state and ceased to write any new business therein. The holders of such policies previously written, as continued in force, paid their premium to the coK^any outside of the state. One of these holders having died, and a contiroversy having arisen as to the liability of the company, one of Its agents resident in Louisville, Kentucky was sent to Tennessee to adjust the �"loss, while there an action wae brought against the company, and a stunmons served on him as the coaspany's agent. This was held to bo a good sorvloe.” In the opinion It la said that "Were the Judgment sought against a foreign oorporatlon Is personal, It is material to esoertaln whether the foreign corporation la doing business within the state^ and, if so, the service of process must be upon sone agent eo far representing the oorporatlon In the state that he nay properly be held In law an agent to receive such process In behalf of the corporation* These requirements were met by the facts above stated"• As heretofore noted, counsel. In hls brief, says that Paul Draper was In Casper to explain to the Wyoming Wool Cooperative Marketing Association "the advantages to be derived from the coop­ erative system of marketing their wool through the Hatlonal Wool Marketing Corporation". In other words, he was In Wyoming at the time of the service in furtherance of the business of the corpoi*ation which he represented. Counsel cites many cases on the question of what is and What Is not "doing business" within the meaning of the corporate laws of the state of 'doming, and other states, yet, in our opinion, that question Is foreclosed in this district by ths decision of the Court in ths oass of McCarthy Sheep Company v. Sllberman & Sons, 290 Fed. 512, In which this Court held that a foreign corporation, purchasing annually In the State of Wyoming wool during the wool-buying season, through agents sent Into the state at the beginning of the shearing season, constituted doing business In ^^omlng, and service upon one of Its agents, who was also Vice President and a director, constituted good service. lhe fourth point made by defendant in his brief Is that the return of the sheriff of Natrona County Is defective* This point, we believe, we could well Ignore, for the reason that It Is net one of the points made by defendant In Its Motion to Quash, It �relying, la such motion, exoluslvely upon the contention that at the date of service It was not doing business In V/yomlng* Counsel seems to concede, In his brief, that the objection Is rather captious and not well-founded, nor does he deny that service of a copy of plaintiff's petition was made upon defendant. The quota­ tion fs«OB 50 C,;r. at ^7 Is doubtless a correct statement of lav, but It Is significant that the author merely says that ths return should show coapllinoe with the statute, and does ndt say that. If the return la defective, It Is neoeaaarlly void and deprives the Court of Jurisdiction. Xt Is well known that returns, If defective can be cured at any time, and, aS heretofore noted, counsel made no point of such alleged defect In his Motion to Quash. The sustaining of the jurlsdlctlcm of thia Court to the plaintiff Is vital. If the Court refuses to entertain jurisdiction the plaintiff Is virtually without resHsdy, because It would mean that he would be compelled to Institute his action in Massachusetts and the expense, as compared with the amount Involved, would be prohibitive. It is not a favor we are asking of the Court, to accept jurisdiction and proceed to hearing of the Case on the iserlts, but It Is something iCiloh we believe we have a right to ask as a matter of lav, as, under the facts in the eases cited, there Is XU) question but that, during 1020 and 1021, Draper & Coagmny were engaged In Wyoming In business. The fact that their method of doing business was Indirect rather than direct should not be of ocntrolllng significance. Respectfully submitted, *AWS5^b’ Tor TTaTn-llTf 7 -7- �IN TKS fflJWHf DBTHIOT OF ■ ; 'IRTOIN AllDv .W' TOB « • * * t •'»>• •<# * »* • » • • «ih« 0 *«•>>»« *0 • ♦JI-# • «>* • • » » « « • • ' ■ t Plaintiff, i ♦ • • < • ■■•■ ■ I * VB * DR/vPBH ) .' s ■ ) &CO!I?AIfT> IKC., a corporation* ' j IMtm&K&tt s 9szsr or bitokdaot oh motion to quabm. «aa orUlmXXz temght ia tto Qtstrlot court Ot Nftt^aa county* Vfyoiain^# sorrloa of swactons vas aada upea one BtttX X* l>raport president of the defesidant oorporatlon. The return Of the eherlff reoltes that aerrloe was uade "hy dsHrorlng to Paul At Draper* prmldent and agent far serrioe of Draper A Company* lao. a true and oorreot copy of the BUnraona,”otOe Defendant In due time filed Its petition and bond for the rojaofal of said eause to this Court* and* after suoh rcBaoral had been effeeted* appeared epeelally herein and moved to quash and set aelde the flwrvloe of awomone and tha sheriff* s return of service on Wie grounds that the defendant la o forolcn corporation organized under the lane of the 3tate of Maseaohuaetts* and that on the 16th day of April* 1931* the day of such cttOTpted service of eu^one* and for a long tlae previous thereto* defendani had not traneaeted or oarrled on any business In the state of tryomlng* and that it did not have any <fflee* a^nt or plaoe of buelnees dnthsid State} and also for; the further reason that the said Paul A* Draper wae not on said 16th day of April* 1931* an agetrt Of Nyoning* and had never been such rigent* state on said d^to defendant la the rtate that he vas la this s a visitor and att«|dUkt at a sie0iMg ot �the vooX Gloverb Aaaooiatlon to apoak to th«M upoa the a<»an« tagOB of tho OMporatlTO plan of marketing wool. By ogroement of eatuuieX for the reapoctire parties> snia mo* tion to r^uaah is sulmilttea to the Court for Its decision upon affi* davits filed In behalf of the respeetlTe parties and upon writtoa briofa. ■ ’I;*' Bxsoessxcm or w The evidenoe oleorly shoes that the defendant Is a foreign corporation orgenlKSd under the lews of the State of Massaohusotts with its headquarters and prlnolpal place of business in said statei th^At it has never ooiaplled with the laws of the State of Wyoming, relative to foreign corporations doing business in said state* and has never appointed an agent f'or service in said state upon whoa service of process might be made* All of these facts are conclusively shown by the affidavit of W* 0« Carleton* deputy secretary of state for the ^tate of Wyoming* The evldenee further shows that Paul a. Draper, the persan upon whom plaintiff attempted to serve process* la the president of the defendant; th; t he was not transactin^s or oarryln^^; on baslnesa for the defendant in thia state on April 16, 1931; that he had never transGoted or o rried on any business for dafondent in this state; and that he was not on said 16th day of April, 1931, or nt any other time, the m^n^lng agent or other agent of defendant for the transac­ tion of business In this state* Further, there Is no evidence to show that Paul Draper had ever been In the State of Wyoxalng* prior to said April 16th, 1931. The evidence further shows that Paul Draper came to Wyoming at said tiiae for purely personal reasons and not on any business or matter eonnoeted with Draper Oompany* He muss here upon the Invita­ tion of the Wyoming Wool Co-operative Marketing Association to attend o convention of the wool growers of this state* which was then in session at Casper and to explain to them the advantages to be derived �eyetea oC aaHcetlng their vooX thrmii^ the Sia* from the tional v<ool tforSaitlng Corporetlon* He case here ae a prlTate Indlrld* ual and not a« an agent or roproseatstiT© of Draper & Oosipany* mo. Thia fact Is of the highest ImportancQ, for, if this aerrloo upon iwl Draper should he held to be e^ood serrioe upon Draper & Company, Ine.» then It would xaeho no dlfferexuie where Paul Draper mle^t sbi> In these United States for pleasure or for other purely persMoX reasons* ser* Ties upon hla la suoh Jurlsdletlon vsuld he ssnrloe upmi Draper & con* pony* Ino., In that jurlsdletlon* a pro^sltlon that Is absurd upon Its very face* Ths evldenoe also shows that Draper a& company, Xne« was formerly eneaged in the wool merohandlslng business with offloes at 281 swa&er Street* Boston, ?4assaehusetts» The erldenee of its offloers end agents also olearly shows that during the ymrs 1900 and 1931 It did not pur« ohase any wool any where In the Vnl^d States, but noted solely as the exolusivo sales agenl of the National tTool L'urkOtlMji Corporation In the sale of wools consigned to said corporation by the different wool growers oo*operatlve organlssatlons throughout the United states. These faots are shown by the affldarlta of Paul Draper, the president of the defentaant, Joseph D» Draper, Its treasurer, end George W« Brown, Its aeereatry and assistant laeasuret* Xn addition to the testimony of these witnesses, Charles X» Tuttle of Salt City, the western representnt Ive of the defendant and a asa In a position to know the foots files an affidavit In which he st^^tes that’ after February, 1930, ^Draper fe Ci^apeuy, Xnd» did not purchase any detoestle grease wools; In ths state of T/yoming or elsewhere in the United tates,” end Charles M, Wilson of isoKlnlsy, lining, the secretary of the rzyomlng Wool co-operative Marketing Association makes affidavit that he knows of his own knowledge that the defendant did not purehase any wool in the ’^tate of Wyoming during the year 1931. From the very nature of his work, 2<ar» Gilson was In a position to know the faets In regard to whloh he testifies. It Is true that plaintiff has filed certain affidavits In idileh it la alleged as a eonclusion that Draper & company were engaged In business In this state In 1930 and 1931. (3) But, as stated In the �preceding paro^aphSt we have here the affidavitb of fire prominent busiaeaa men oaoh and every one of whom Is in a position to know what are the fnots la rogaM to the defendant osrrylng on boslness In this state In those years and eaoh any every looking affidavit that the defendant did not purohase any wool In this state or elsewhere In the united states during the year X031* Oan this court helleve that men of tha hl^ httslness standing of these mn wmild oomlt perjury or teetlfy falsely la regard to this matter* and to do th^t especially la a ease of this kind where their testimony eould so easily proven IM be false If It were untrue? If Dwaper company* Xno* had bought s single wool ollp In thlc^ state during those years* the records of sone express office or freight offloe would show the shipment of that wool to the defendant and the solXer of such wool could also he obtained as a witness to pr^e such dale. Onder such olrowstcuwes It Is absurd to contend that ths defendant purchased wool In Wyoming In 1930 or 1931* Tt is true that ths plaintiff hs» asde s fe^ls effort to ever* e<»ss the testimony of these wltnessesa one Jflueass He has filed the affidavits of Cunnln^aa end one Alex Healy to the effedt that each of thm knows of his own knowledge that one william y, Klsslok was tta* ' >leyed by and solicited business for xsm^er h Oompanyt Xnc* of Boston* Mss8« during the wool buying season of 1931.” Weithar of these affi­ ants sh0W3 or attempts to show In his affidavit by what means he has actual knowledge In regard to who ar© the employees of a corporation whoso offices are located In the City of Bof>ton» more than two thousand nlles away. Neither of these affiants states where he resides or what his oesupetlon may be« ?xt thia point* we wish to call the Court's attention to another significant fact about these affidavits. They both allege that the said Klsslok solicited business for brapsr a company* Xnc. In Wyoming. I^ey do not allege that Klsslok bought say wool or sKde any oontraot of any kind for and In behalf of the dtifendsnt. Xf It be e fact*as etsted by these witnesses* that said rlsslek aoUolted the sale of wool la beMlf of the defendant* why Is plaintiff not able to produce one single wool grower to make affidavit thnt the defendant purohf.aod hla wool O3?op during the year 1930 or the year 1931. ( d ) The reason of oouree �It obTioue* riaalok did not Rollolt the parchaae of or purohese &)17 «doX for dofeftdant In thia atate In 1931, hut, as stated In ths Affldw&t of Mr. Charles V ■' ■i-K:-. --/'.- ' V ■i. ' Wilson, said Kleslok « ttoXlolted ce3rtr?in wool erowors of ths state of WToalas to heoQBKS mer^hera of ti» Wyoming wool oo-operatlrs Karketlnf; Aesoclf^tion and to market their wools through said eorporatloat ©nd that acting for and in behalf of arid Association did contract to puxKJh^se and did puroh?3ae tQT aeld Aseocictionjoortaln orope of wool In the stat© of in the y@£^r 1931,** This la the ststSEiont under o th of a mfln who is willing to gf.n hie raaldottoa snd ocoupf tlon f?ad to state fnots eo that the court wiy see and uadaratanfi that he la In a position to fcnftw the mots In regard to whloh he la toatlfylng. HSr. Wllaon Is the secretar/ of the wyonlns Wool CO-Oporativs Wtrkatlng Aasoclatloh. Mr, Klaeloic worked with hl« In 19S1 end under his directIona as an assletant seeretary of said Aasoelr tlon, further «r, ^ly^s affldartt stetsd that Mr, Klsslofc la now In hie e^loy. Where le Mr. KlseloJt'B affidavit ss to -;at»eh'affM»wlt eOnld Mva Ossily hsa* •htalaod hy pltslntlff and ho could have testified to ths fasts and to oonolualona, , lOalatiff in his oral testlttonsr in open court tried to leave f the inpreoslon with the Court th^t he was still in the employ of the defend.mt and la support of his olaia that defendant was engaged la business in ^yeaiing during the year 1931, ho Introduced in evldeaee a ^to i^mriag <^t upon the door of plaintiff*© office in the Henning (Hotel in «»e City of Gasper appeared the words " Representstlvo of Draper & company, lao .” Hut plaintiff*© oral testimony also shewed that he had purehased no wool for the defendant during the year 1931 or aftn? Auguot, 1930. Plaintiff also adaltted that all the wool that he purohaeed during the year 193G ©nd during the very tlae that he ol^las that he wae employed by the dofwdant and for uhloM serrloes he seeUs to recover In this action,wa8 palA f»r by hla with Irnrts arsw bf J»l» MPsa W wool Uarkettnp; Corporation oBd IHat hs was sa B|Wi«lBa». . sogretary of ths wyoainc wool, Co«0p<pfat ire order thAt ho might teaw suoh drafts la the j^gas of said Aen^latlo^ In i^ynent for the wool so Plaintiff furtbar tootifioa �to pwrahese vOol during the Ihatt all wool growars from ha season of 1990 thavahy autozaatiaally haooao osabers of said Aaaoolatloa* ibafaskdaaat does not aara at thia time to go lu^ the marlta of elalm ngalnst tha dafaadaat> ^t oartalnXyt if tha persona irtko oontrnoted with the plaintiff to sail their wool oUpa through him In tha year 1930, hy auah contraot and sale haoana aamhara of tha mins Wool 0o*0pe3ratlve iTarketing /^sTOOiP^tlon# end ware paid for their wool with drafts drawn in tha name of said Asaooietion upon the National Wool '^terhoting Oorporatlon» it is mthaa? hard to undorstaad Just how Orapar & company* ino* by these aots oaa ba said to ba doing bueinaaa in thia state in the year JU^SO* X>afondant also wiahae to oali the Court*a attention to the taa» tiaony of Paul Draper to tha feet that if the plaintiff had had tha 'mum Of Draper & CompanyIno« plaoad upon the door of hie offiot in ,/ Caapar sM had edrartiawd himself as agent of ibmpar & cotapnny in tha by Uia Henning HOtalt that such sots ware entirely without tha knowledge or authorisation of tha defendant* surely plain* tiff oan not bolatar up his ccse by auoh rapraaaatations, whieh* so far ns the erldenoe shows* were probably made after tha controversy had arisen botwaen plaintiff and the defendant* Xn our consideration of the oaae, we have not overlooked tha affidavits and depositions of other witnesses In behalf of tha plaintiff* but oa wa view It such testimony Is too indefinite to have any probative value* the affidaylts Qt Morton* J'* Walter williaas and Fred Siamma are to tha affaot that certain individuals came to them In the year 1931 and represented that they ware in the employ of tha defendant aaft W to tfeq aefe^»«tePt but to the Wyoming wool cc^Opagatiye fferteatlng Aseeaiatloa* these affi* davits support tha alaims of defendant and tha stntanants of its wit* ; masaas and aepeolally tha affidavit of charols it* Wilson* Further even if these perties did represent to affiants that they were in the employ of the def endent, such representations are not aompetont to prove agency* No rule of law is better established then thia* See 2 corpus Juris* Page 935 and authorities there cited. the affidavits of John P* Nolan* Arthur TamuXaro and Bony - Mahoney are also of no probative value* { ^ ) They merely show that one H. a* �Bennett drew oertnin iirev oertatn drafts upon t&s defendant, tsr. 01uub« M« Wilson testifios that Besinett was sent out here hy the Katioqal wool Marketing Corporetlon to relue wools purolmsed by the Wyoming Wool Co»Operatlve Marketing Assoolation and that he solieited busi* nesfl for said Assoolatlon and was rippointed an asolet'int secretary of said Association. Owing to the close relations between the Na­ tional Wool Marketing Corporation, the Wyoming Association and Draper Company* Ino., there is nothing about these drafts. Kwea if it be true that he purchased on autoaobile for hinsolf and paid for such car by a draft upon the defendant* such fact is clearly iasuffieient to eatablii^ agency* er to prove that Draper & Company* Zno* was doing bueine^js In the state of Wyoming in 1931. AS has Wmi ixsretofore stated* i^ Drajker h company* Zac. did ?Any buBiness of any kind in the state of laming ia 1931* and if Bennett* Kissiok or any other party was really engaged in the trensaotlon of bUBlneset fer'l?raper^ company, Tne. in thia state in said year* it io oort tlnly passing strange that with the number of witneeaes who are willing to swear to such oonolusions* plaintiff is not able to produce a single witneea who transacted any business with Draper & company, Inc. in thia state during that year? and* what is still :nore remrkable* plaintiff’s witnesses who testify so glibly aa to these various persons being employed by the defendant* are not able to testify affirmatively to a single sale* a single purchase* or a single contract of any other kind* whieh these alleged agents of the defendant entered into in behalf of the defendant in this state during said year or the previous year. Surely these alleged agents of the defendant must hove been very poor aolioltora* if they did not enter into a single contract in behalf of their principal during one entire ycara plaintiff has not produced a single witness who has testified to a single Item of business of any nature transacted or oarried on by the defen 'ant in this state during the year 1931, The affidavits of plaintiff’s witnesses state mere conelusionfi* instead of .^tatln^: ff^cts from which the Court mey be able to draw its own conclusions as to whether or not defendant was doing business in this state during said year* �under n state of ths evldsnssf ho* ssa this court or any uourt find as a fact that ths defaadaat was doing huslnaas In ths itJtats of WjKnalng In 193Xt Or srsa la 1930T if ws think of ths dsfsn- daat as doing huslnsos la Iddts stats during that year* thsss <£uaetlon8 natUThlXy arise* Uhat huslnsas was It carrying on? head :uartera? whoa did It do buslneso with? that business? Were were Its What was the nature of What property did It have In this stats? mneglng agent In this state? eto» Who was Its Plaintiff has not answered these or any alnlXer questions in any of hla affldavlta filed herein* Can this court answer a single (ms of sueh questions Intelligently from ths srldenee adduosd by plaintiff*? And yet ths court must do this. If It should otteopt to find that the defendant was carrying on bU81«> assB In this state so as to render It amenable to the servlos of prooesB herein* The affldavlta filed In behalf of ths defendant stats facts and not conclusions* Vr. CfhftWes M. Witscm In his wffldevlS doss not deal with generalities but states spsolflo fasts from wblsh the Court zaay be able to draw Its own ooncluslcms* soys that he larked with these various parties who are alleged to have been agents of the defendant In 1931* and he tells the Court Just what they did and how they oame to be employed In this state* He says that Bennett* Klsslck* Bannon and Blchards* the G»n who plaintiff claims wore eawi' ployeoe of the defSudeat la this stats In 1931* were wool sag^rts furnished to the Wyoming wool co*Operatlve Marlrating Association by the National Wool Marketing corporation under the tertas of Its eon'* tsraet with said Corpomtlon* to appraise the wool xAirchassd by said AsBoelstlont that eash end every Of said persons were appointed assistant secretaries of said Aoeocletloni and that acting for and In behalf of said Association* they sollslted the wool growers of thia state to become mM^rs of said Asioolstlon end they oontmctcd to purohase and did purohase as agents for said Aesoolatlon certain crops of wool la �Wilson* s affidavit shows exeotl^r what these laea did and by whom they were employed and hie stutemonts are oonflrmed by the affidavits of John R. Morton and J» Walter Wllllaas» two of the wltaesBOs for plaintiffs this state* These men are j;n!<»alaent wool growers of *raHiy state that la the iaonth of June, 1951, lu H* Beaaett sollolted and approached them and requested thett they ship, oonslga or sell their 1951 wool crop to the Wyoming wool co-*Oporative Maxdcet* Ing Corporation and stated thf^t he, the said Bennett, was securing wool for sold Association. W. Morton i.nd Mr. Wllllaas are plaintiff’s own witnesses* Further, in this connection, we wish to call the Court’e attention to the second affidavit of Mr. Paul Draper filed herein. In thnt cffddavlt he states thet his attention has been called to certain affidavits filed by plaintiff to the effect thet the said Bennett and the bald ElsslsM ''had sollolted certain resedeats of Wyoming during 1931 to sell their 1931 wool ollp to Dxraper & C<^x>any, Xao.** speohing ae president of the defendant, in his affidovlt he eeys "that nelldiew the acid Bexmett, nor the sftid tisslck, nor any other party had any power or authority to purchase wool, or to solicit the pureh^ise of wool In behalf of Draj^r & Company, Inc. during the year 1931. And he further states that "If any such solicitation was made by th© said Bennett or the said Kioelok, it was nade without the consent or authority of said Draper & company, Inc." It would hardly seem to be necessary to disewas the evidence further. It conclusively shows that Paul Draper was never the taage** glng agent of the defendant in this state, or Its agent for service of process s tht^t he was In this state on purely personal affairs in April, 1931, at the time that the attempted service of sumons was made upon him in this eaee; and that during the years 1930 and 1931 the defendant did not do or Carry on any business of any kind or el^raoter in this state| and that it was not engaged in business in Wyoming on April 16th, 1931. For theae reasons upon the evidence alone, the service in the onse at bar was and is insufficient to con* fer Jurisdiction ux>on this court. �A BBOT Rsrio 0? ran vnmiwo ctatotbs rsutite to swricex UP0» mSIGW COHPORATIOHS. rae sexvioe in thie esse van mad© bjr sheriff of Katroaa aountXi WspofflizM;* u><m proeesa issued out of the Distrlot court of that oounty* In the f'tate of Wyoming there are four different stat* utory proTisions relating to eorvlco upon oorporatlonse seetions &048 end 5044 provide for the appoint^nt of a statutory agent for serviee of proeess* Those seetions ^^re inappXioahXe here heeause the reoord is clear that no such statutory agent for servioe was ever ^^ppointed In this state by the defendant which is a foreign corporation organised under the laws of the state of Massashusetts* Of course, the return of the sheriff states that Paul Draper was the agont for servloo of the defendant oorpor- tlon in this state* This, howeveri is a aere eettelMiea the eheriff unsupported hy the f^icts, as the affidavit of the deputy seeretary of state oonolu* aively shows that defendant had never appointed any agent for eervioe of proeess in thia state. The Wyoming Civil Code eontains two seat ions relative to service upon corporations end in the abaenee of the oppoiataent agent for eervioe* these sections oust eontreX*^ They ere ce followsi " ^^eotion ^031, A owamdtts against a oori>oratlon nay be aorvdd upon the president, mayor, ohaimnn ot president of the board of directors or trustees, or other chief officer, or if its chief officer be not found in ths county, upon its cashier, treasurer, clerk, seoretrtry, or osneging agent, ’’©to* Sectiou 5433, When the defendant is e foreign eorporatioa hewing a ■anagiss agent in this state, , the serviee any be upon autdx ^ifroat,” rates provisions of the Wyoming cod© were t<<k©n from the Civil cede of the state of Ohio, and the general rule of construction is that when the legislature of one state adopts the statutes of another state, it also adopts the construction placed upon those Btetutes by the courts of that state. The courts of Ohio have always Iwld that these two sections of the code are not only separate and distinct, but they also hold that Section 5631 applies exclusively �to 4oB03tio oorporatloBM and that Sootloa 5053 applies exclusively to foralga oorporatioas * Xa the ease of Goode * DrugKdats Aosoolatioat Id Ohio neo * the court said that ** Xt is the aeoopted role in this state that seetions 5041 and 5043 of the nevised statutes rolstlnc: to sorvioe upon a eorpopation are exeluBlTe of each other, and that seotion 5043 provides the only means of obtainiTi^ eexe^ioe on foroi^'n corporations * *• W’ •5 in the sane case It was held that "In order to sustain service whioh has been made on an offioor of a foreign corporation, it pust be made to appear that he ia the mayger of tSeT^uaynyse oori^rqtfon^ within the state * or come" suSs^^ Th© above deoision of the Ohio Circuit Court is referred to in the case of Beach v. Turbine company * S43 Fed * 706, and the Court in the latter case says that it is a correct statement of the lev of Ohio relative to service upon foreign corporations * Xn the case of Foote v« Omtral Aaorieaa cennraeroial Co , * Ohio C« D. 376 * Id the court held that a director of a foreign corporation who was in the State of Chid collecting payments on suhaoriptlons for lands was hot a * managing agent ” within the purview of the above statutes end that service upon such director was in sufflo lent to con­ fer Jurisdiction upon such foreign corporation * Xn the case of state ex rel * 7 C * * C { N. S. ) 557 * the return of the sheriff recited that the surtnons had been served upon one said company * Kilis v« King Bridge Ooxnpany * X. Riggs, the superintendent of he being in charge of the usual place of doing business ot said coE^any,” The court held the return to be defective and saldj *• There is no averment in the return that M. X. Biggs is the ffl^naglng agent of said company. He is deacribed merely as a Guperintendont« This doce hdt appear to be a proper service and tlw aotlos to quash service **** '* ^ * ’‘* must be sustained *** Bafondant will admit that the deoisions of the Ohio Circuit eourta which are Intermediate appellate courts ere not the highest authority but they have been followed in the U * fl. District Court for the District of Ohio, and they are cited here to show that under the decisions of the Ohio courts involving a statute identical with the Wyoialnr: ritntutes under which service was atteapted to be mode in the �oone at bar, afUtth eervice an4 the alwrtff’a return thereof would bo quashed aad de SuoaffMleht to confer Jurisdiotlon owtr the paraon at the <tof«i4taiat foxeisa eorporatlon. suoh‘ holding of the Ohio oourtB would undotthlodly ho followed by the oourta of hho State of Vanning where thle suit was orlglBslly brou^t end la whleh thio serwloo ?«al VK^er wae aerer the 'lHaa<bl« agoat" ttttnphed to be nado. of the defendant In this atfite and newer had anything to do with the transaotlon or carrying ot of any bualnesa of the defendant In thle The serrloo of swb^jbb upon hla and the return of the sheriff state. are both clearly insufficient under the laws of the state of Wyoming, and being Insufflelent to confer Jurisdiction In the stoto courts, they are Insufflelent to confer JurledictIon on this Court* ; 'III . mrxw Of WK W TSDfflAL CISBB WaSKS 1 It would hardly aow to he nccessarz for the defendant to prolong this brief as its right to hnvo the relief aeked for in It# motion to quash has boon clearly doxoonstrated In the preceding pages hereof* However, wo will call the court’s leading federal decisions where this sfias t tent ion to some of the uestioa has been raleed* supreas Court has oftmi announced the prlrolples of law applicable to this and cU alxailar eases* Ono of the latest decisloae by that court Is the ease of Rosenberg Bros* a C3o» 6? t* Curtis Brown co*, BOO n* s* 316, 373, with opinion by Mr* Justice srandols* Tn that esse the dofendant was an Ohlahoos corporation dealing in »oa*s clothing at Tulsa in that state. Its president was In Sew tork tompomrlly ehen he wns served wlto process in a dd action. It was aliown by the evidence that ho wae in Hew York for the purpose of par<^sing goods for th© corporation at the tlao ho wao swrvod with j^oeoos* The Cletriot cowt granted a notion to quash the service* and on appeal to the V. S. supremo Court, the decision was afflxned* The court, saidi " The defondaat acrer applied under the foreign corporation �Xciini for a llotnaW to <o bxulnoe* In wr Tneitf nor dlA It at any time euthorlzo suit to bo hrou^t against It there* It nererhad an established pXsee of bialness In now IRirlu nor did It regularly oarry on business there* Tt had no property in now Tori and no acoat, officer or stooh holder resident there* Its only connection with new York appears to heve been the piwehase there from tlzae to tlzae of a large part of the Borehahdlso to be sold la Ito store ot TuXea* ” The suproM Court also said that It was of little legal sig* nlfloaaoe tdiether the president wns there to buy goods or not at the tine that he was oorrod with j^reeoee la s^jld ootloat that rlalts of the offloera of the eompany on such huelaooo eymi If oeeurrlng st regular Intervals» would not warrant the Inferenoo that the corporatloa was present within the jurlsdlotion of the state* The court also said that as the corporation was not present In the state and doing business therein* the fact that the eauae of action arose within the state was Inaaterlal* In the late case of Pedple^s‘l^baeee company v« lasrloan To* huaee C($ksU9eay* V» 3« et» Oe 1* Xd* the supreme Court said tluit a cox^joamtion oan be acid to be found la a district only when It Is prepoAt In that dlstflet by Its offieersmd agents carrying on buetoess of the eor- nation# And in the ease of Green v» C« B« a Q* Railway company, son n* S* 51 !• Bd» Bid* the Court eanowneed the rule that pare pollcitetion of imsineee within a etate je not sufficient to ocnstltute ctoing business in tho sense of Inourrlng liability to warvlce In that JuSla^qtAonj. A case very aiallar to We case st Wr Is the ease of Sslsukas ▼. OrMsemgh Rod Ash Coal Co** Add U* S. Sd* dl U Bd. 937* Ihe opinion was by Chle< fUstloe Vhlte« Xn that ease Were had been an attempted aervloe Bads upon the president of the defendant oompany while he ima toepmwdXr W York City* The eridomoe showed that the corporation had no property or place of business in the tat© of New York* that its president ms in New York only temporarily and was not there engaged In the transaction of any buslnass for the company or on its occounti and that he had no authority to represent the corporation or to transact any business In Its behalf in New York* Ote sezvlee wes quashed and the supremo Court held this to be correct* ( xa ) �A&a tn the ease of Peterson V, Chtoage* Book leXana & Peolflo B' tlway co»» £09 IT« s. 364, SI u sd, 84Xt the Court saitd; « Xt ts settie^l by the deoletone or thSh couit that fO3*olgn eorporotto&e oan be serred with prooeas wlthla the strata only when doing bun Ineos therein, and auoh aCTTlee aiiet be upon an agent who yeiapesents the ooripornttoa by.£jlxie33,>‘'' While there are may more deololona of the “uprono court In vhloh thle question Is Olacunsodt w do not believe that It la nooessary to review or quote from further authorities. If defendant should oonoede as fully established by the erldenee every ooncluslon In every affidavit filed by the plaintiff, every etatewent contained In said affidavits as to what some one told somebody 0X00, yet even then plaintiff bos failed to bring his service of proeeae In thia oeee within the purview of any of the foregoing authorities. If Draper & Company, me. was doing business in Wyoming la 1031, as plaintiff has attempted to show, suoh business even eeoordlng to plaintlff*8 witneem was being eonduetea by Bennett and tnsslek. There is not one word of ebidenee to show that Paul Draper ever rexmw* sented the defendant In this state In any way. Therefore, the servlee made upon him was Inaufflelent to oonfer jurlsdiotion over the defen* doMt, for, es said in the Peterson oase, supra, ^'service must be made upon on sgent irtio represeats the oorporutlon in suoh business.« yurther, therj is no evldenoe in the ease at bar that meets the requirements as announoed by the Supreme Court in the ease of Rosenberg Bros, co. v» Curtis Brown Go., supra* Parax^^sixgthe quotation from that onse on the prededing pages of this brief, The defendant nevor applied under the foreign corporation laws for a lleense to do business in Wyoming; nor did it at any time authorlTie suit to be brought against it in said state. It never had an established plaee of business in ’’yonlng; nor did it regularly carry cm business there* It had no property in wyoialng, and had no officer, agent or stockholder resident there* The defendant might well rest its ease upon the foregoing deeislons of the supreme Court* However, It will call the attention < of th« Court to three dec is ions of the lower federal courts. The pXaihtlff when testifying in his own behalf as a witnees stated that the defendant sent its agents Into the In^et and appraise wool. tate of Wyoming in 1931 to Wtiile this statement has bom shorn to ho �contrary to the fttotn* yet* even If the Court should believe suoh state* aont, aueh aetlon on the part of the defendant would not constitute doing bualneae within the atate* In the oaee of Michigan Lubricator Co* Ontario cartridge 00*1 275 rode 902* the plaintiff had entered Into a ocmtraot with the defendant for the oanufaoture and sale to the defendant of a large quantity of brass parts for prlners for i^eXle which were then to be Qonplotely sseeabled and loaded by the defendant and then sold to the Kddystone Company* The contract provided that these brass parts were to bo nnnufaotured In Detroit and then dsllwered to the defendant at Its place of business at v/alkeravllle* Ontario. The defendant seat agents to Detroit whose sole bpslnees was to Inspect these parts as they were aaaufaotured by the plaintiff before they wore shipped to defendant. The circuit court of Appeals of the sixth clxeult held that the furnishing of Inspectors by the defendant under such elrewa* stances did not constitute doing business la the state of Michigan. Ona of the very best discussions of v/het constitutes doing business In a strste by e foreign corporation so as to make It aoenable to service of process in that state Is to be found in the case of Tllmmem v. Dodge Brothers* 21 Tad. (2nd) 152» In that csae the court quashed and set aside the sexwice of ouraiions. In its opinion It said: " As already pointed out* it is not any business activity which will constitute the necessary ’doing business.* Bcf* erenee to adludioated oases shows that ;Uite generally it has been held thr.t ’doing imsiness’ is not shown by the mere solicitation of orders through employee* oven thi^sugh from an office employing in addition several clerks tad agents where corporation has no property in the state other than the office itself* and where the ooxporr tion In the foreign district passes there upon irtiother the orders shall be aooeptod or not* and* if It does Gooept* deals directly with the cuttoner; nil transaotions being oonpleted out of the state where tho orders nre nolicltod* and where th© agent does not iKive authority to bind the corporation. (Authorities) This is of course ce rrying on business of « oox't;=in kind and extent* but It Is not the carrying on of business by the foreign corpora;! ion ’ in suoh a manner and to suoh an extent as to warrant the inference that it Is present there.* * * • Mainten nee of an office in the district of suit does not neoefisarily conotitue doing bualneses now* on the other hand* does failure to melntaln such office moon that the eorporetlon la not doing business In the district of suit. { Authorities.) Listing of the corporation’s name in the telephone directory, or having its naa» on the door of an office* does not neoesearlly constitute doing business. ( Authorities.) The corporation laust be eyaged in cyrylnr^ on in a manner g aupaty of it'a ordin^y for toIoK "ft wee ( Authorities/) it io thtf manner, �extent and ohnraoter of the sotivltiea Qt eorpomtion tn the dietrlet qT suit whloh Is detenatactlve. T.wreXx Inoldantal and eoIX^^teiaX aotlvlties vtXX not sufflee# ( Authoritioe.) AdrertlainGt will operational mlnton^noG of en office, listing Its n^me In the telephOM dtreotory, or h^vln^^ Its none on a door, while aaterlal, do not neoessasrlXy ooaatltnte ’doing huetnesa*’ * ♦ • ♦ Ao shore stated, no general rule has been In Id down aad eaeh aaae wst depend cm its own faote and clrousw staneea* The poUey of the lev is that a defendant Bay be sued only in the distrlot in which he ia sn Inhabitant or in which he la found, which in the ease of c oorpomtlon Means that it shall be fairly olearly ahown that it le ’doing business’ in the dlatriot In the neaning vhioh is given to that expression by the deolalons* Under section 48 this Jurladletlonal requirement is expresoly etated tihe burden la on the eomglalnlng party to t^ow tjtie lurlijloi'lQi^Tfae^s * ~ .tEUUESa We latost ttot can be said to support th© jurlsdlotloa under the fr^cta in this case Is that it is extremely doubt* fttl» m thia situation it ia better that the prirtioe b© remit* ted to the district where there Is no doubt as to the Juris* diction, before, rather then after, expensive and protmeted litigation hoe been had.” ( Authorities,) Tim last paregmph Bight have be«a written in reference to th* e*^ et bar for each and every word Is applicable to the fasts as shorn by the evidence In this esse* If tho motion to quash be sub* tained, it does not deprive plaintiff of his reoedy. It only relegates him to those courts where there can be ao question of jurlsdletlon raised by the defendant. This leaves only the cose of McCarthy sheep Co. v. silboraan and Sons, 290 Fed. 512, for our oonal derat ion. in that ease, this Court held that service made upon the vlce-praaldent of the defendant eorporation waa ^d servioe. But the facts in that ease were Bsterlally different from the facts in the ease at bar, beoauae in that oase the vloe president of the defendant, David silberssan, had his office and head quarters at Casper in this state, and was himself engaged la purchasing ami at that point for defendant end performing other services for the dsfondant in the state. In that case, also, drafts in paisaent of the wool purchased were drawn upon the defendant and the wool pur* chased was consigned to the defendant In Chicago, On the other hand, in the oase at bar, !4r, Paul Draper, though president of the defendant, had no office or head .uarters in thia 0ate end was not at the time of servioe and never hod been engaged in <uxy bualnoQB in thia state in boholf of the defendant. The drafts In payment for the wool purchased by the alleged agents of th© defendant Bennett and Misslek, and even those used by the plaintiff himself, were .., .(J . . .■ «> - - ■ ■ < ' ■ ■- ' t'-A ■' �J. ’ ' A?.'-'.'-?’ z*': '■■'.■ ■ algn<a b7 all ot tMea a^efi^ not aa te/^■'Wim «? the tefaadaxit, agents 4» - 5- i '> '■ bat a« oatlW^ai ''' , ' " j. ®? tlwi '^yoalne ifool c<>Oporatlvo l^arketliig Asooclatloai aa4 tM toafts drawn by thaso parties la payment for the weoX purehaeH Weve nywa the defendant hut upon the National vool MnrXetlns Cosrporat loa* emd the wool purehaaed by t2mi wa« lUilpped te the National Wool Marhetlng corporation* The natloneX wool Marketing Corporation paid theee drafte axil ehergOd them agalut the aooount of the WyOKzlng wool co-operatlwe Mrketins Aseoelatlont vhieh in turn eharged the eeweral drafts to the reepootlre aoeounta of the grower meahera of the Aaeoelatioa who had produced the wool th«« cold* Wortlxerg the erldenee ahowe that the defendant had no offioe* no plaee of hu«lne«e> and no praperty in thia state* we sail the Court*s attentiC^ th ^eee faoto> eo that the Court nay see end under* et^nd th^t the f^^^cts in ths ease at hex are not at all like the faots la the KoOurthy Sheep Cotnpany oess©i *md th^-t th© deoleion in thct caee is not oontrollin^ la the ease et bar* hut that thia osee ooaaee atrietly within the njles as laid down by the S^reme Court in the oases whioh we have hereinabove reforred te> assftj|h>*wislly within the rule as laid down in the oaae of Sincere w« Dedc^ Wwthera* • *:/ ■ ir. TOs rawRN or THK ^mEKiy? m w^taixy defscyiyb aot is ikbuju FKJISKT TO COWySR JOTISDIOTIOW VPOB TOX8 COW* ^ile this ohjeotion io not definitely eet forth in the notlstt te «es«h filed by w d^eiMbwt to rn® eotion* yet mid motion aska the Court to quash '^nd i’ot nside the WM’sons and the sheriff* a return thereoxst and for that reaaon we believe is suffloimitly broad to inolude any substantial defoete in said return* The sheriff’s return roads as follows: ” the J5tat0 of Wyoiaing ) ^uaty of Natrons I Be. ) X> 6» 0, Housley* sheriff in and for said eounty in the state oforesaid do hereby certify that X s^eeeived the within Bumows at 3:10 o’clock P* TU es the 13th day of Aj^iX* 1931* and served the same on the 15th day of April* ■- �President 1931 by deXlTorlns to Paul A. Draper/and a^-@nt for service of Draper & Compeny, Xno« a true and oorreot eertlfled ^9^ the sfuae# vritassa tend thie loth day of Aprilf 193X« By It, a< o« HWeleyt Sheriff E* Decm> Deputy* *• tie noticed that the sheriff* s return does not state where the serrlse was aad»> or that a copy of tlM petition In said action was served upcm the defendant* The Wealns statute rehitlve to ths service and return of suzivno&s la QS fellows: ” servlee and return of summs* servloe shall be by delivery at any tl»s befere ttie return day» & espy of the suacjons with ^e ^doraenents t^iereon* together with e of the petition to ths defeadent personally, or by leaving a oopy of the sisa^hts azid petition at his usual piaoo of rssldenoe >»»***♦♦ aj^d th© return nuat bo aitdo at the tiise mntloaed In th© writ*, and the tiao and laannor of sorvloe shall be stated in th© ffrlt.” While there say be sc«ae uestlon under th© authorities as to the nsoesslty of th© return stating that th© sorvloe was cotually laado la Matrona County, ’.'^yoLiini’, ths hotter practloe li; for th© rsturn to show where the servlee was nade. On the other hand, there eon be no xuostion that s retun which fel3« to show that th© copy of the maamoas served upon the defnau* daat sontalned all th© ©ndorsenents or lhet a copy of th© petition was served upon th© defemdsnt, vdiers suoh servloe Is reqtlred by the ex* press provisions of ths atetute, Is fal^lly defeetlv©. Th© general xtile la thus atatsd in 5o Cerpu© Turia* page BbV, ** Wl^re It la required that a copy of the|i' petition or iK>mpldin| bs^ibllvered to or left with the 0fdadaat * ♦ * th© return should ahow ooinpll«inoo with au<^ ro* ulrexaeat,’* defocta in th© aervlo© Qt auui^na md petl* tlon ©x^ t^ sheriff’s return ar© dofeot© ttvit might possibly b© cured end for that reason are probably not so vital and do not go ao ooxn* pletely to the Jurledlotlon of the court, as the defeats urged In the preoodlng aub^dlvlelons thia brief, yet the defendant feels Justified in oaHing then to the Court’s attention at this tiae, beoauae It la very doubtful whether auoh defeets In the return of the sheriff ©an be cured In thia court, for the reason that th© sherllf is an officer of the state court and hla return wee aade to that court* ( IS ) �since th© ferofiolag port lone of thia tolot vox** vrlrtos* «• aeoKlaQtally learned that the pXalatlff has filed a lort’Q number of additional affldavlte in reletaaee to defendant's motion to quash* Under the egreoMBt of ouunsel end the notloe fxou this Court eaeh side was given until Januery Sdth, 1932> within vhioh to file in this court and aerre upon opposing oomKsel any additional affidavits which he ffli^t wish to file in this nt- tter. Xn oonfomlty vlth that agremnent, counsel for the defendant on January S3, 193a> sent by registered mall to the attorneys for the plaintiff copies of all affi­ davits filed herein by the defendant or In Its behalf* He received BO affidavits of copies of affidavits from the plaintiff er his attor­ neys > but on January Sftth, 1932, received frcm the Clerk of this Court & copy of the affidavit of Boy B. Minty filed herein, and he had reason to believe and did believe that this was the only additional For these ro^iaons, such additional af­ affidavit filed by plaintiff* fidavits have not been referred to in the preeeding pages of this brief, and under the oircunstnnoes, defendant respectfully subzaits that in all fnlmess such additional affidavits should not be eonsidered by the court in asrrivine; at its decision* We have glanced over said additional ffidavits and while we have not had the time to read then over carefully or to analyze their contests, we believe that wo are Justified in aoying that these new affidavits, like the ones first filed by plaintiff and which we have diseucsed in the foregoing pages of this brief, state merely the ooncluslons of the affiants r^nd do not state the ffiota upon whieh each boacluslons ^re based*' ' The Court of course rooogniaee that there is a vast difference between proving a negattve and proving an affirmative* Xn this case the plaintiff has the affirmative of provlnf^ thE^t defendant was 'doing business* in this state, and that Foul Draper was not only the president of the defendant but that he was also the person who represented the defendant in its business transactions In this state* see Peterson v* Hallway 0O« and the quotation therefrom on nige 14 of this brief* �He ean act prove these fnota by nerely nXloglng that w» en- goeed tn bualaeaa la sryoalnst as euoh stsiteaant Is e oere eonolxieioni neither ©an ho prove those foots by flXine affidtivlts to the offeot that Doanott, Mieaioh vt al* ww* tsapl»y»®« defendant, for even if that were true, it wouM paon nothing, or that euoh pereons eolloItod buslnoee for defendant la this state, for that Qiao would mean nothing, unless it be further shown that they entered into oonti-sots of soete hind in brtjalf of the defendant, as we have shown, the supreaw Oeurt has held in the ease of Green v, hallway co. 806 n* S, 880, that the aero solicitation of business within a state is not doing business to said Bt:.te, 30 as to subject a foreign corporation to the servloe odP prooesB In said state* The offleers end agents of the defendant In general eharge of Ite entire bualnese operations toatify positively that the defon* daat hod no offlee> plo^ of hufilness or property in the rtate of Wyonlng cind that it did not transact or carry on any business of nny kind la said state during the yearn 1930 and XtSlj and they further testify that Paul A* Draper wae In Wyoming In April 1951 for purely personal reasons and not on any matter of huaiaees for defendant* in addition MT. Brown, the aeeretery of the defendant, etatee that said corporation had never authorised Paul A. Draper, or any other person, to represent defendant in this state op to act as its agent there* To overcome the feree end effect of these affidavits, the plaintiff Must show effimatlvely some hueiness trMsaetion of scaae kladt some contract made and entered into, or acm vork carried on hy in tiile sUto, hefore the Court would he authorised to find that defendant was doing business la this state la the jwi 1830 bM 1931. And he is also obligated to show effinBstively that mul A. Druper wae la charge of such huelaess operations of the de* fendaat in thle state in the year 1931• Plelatlff has filed numerous affidavits in this action, hut in not one of those affidavits is there mention of e single pur* ehase of wool made hy the defendant er of a single ooatraet of any kind entered into hy the defendant in thia state la 1931. Further, defendant has no hesitation in saving that plaintiff can not show �one single pureh:bo of wool niade by defendant in this state in X931> or one sinaXo shiittent of wool oonsiened to the defendant froa this etate in said yeoft or one single eontraot entered into by the hsaid year. further not a eingXe witness has testified to a single set of TauX Draper that eouXd be construed as showing or tending to shew that he was in eharge of defendant's basiaess operations in this BtQt©> or that he was in this state for any other purpose than stated in defendant’s affidavits fiXed herein* MthcM further orguwsnt, detezWlant respectfully submits that for each and XX of the reasons hereinbefore set forth* ite motion to quash and set aside the service of aumiiona and the sheriff’s - return of aervloe should he sustalaed^ �4 = , SH TIIE DI3TR10T StmiN COTOT FOR AND TO 0? THS OOTW) DISTRICT STATS8 OF HT01£D«J. ' '.I MIHTT, ,>:;;.>lOU3er>, » ■r «z\’ ■\' •"•■- 1 - TB • Ay DRAPSR <OOlfPjUlYi W. a Corporation, Defattdant < •- ^3 .' '’■'•te ft 1 T I t 9 The state of Wyoming, ) : ae Oonnty of Larenle* ) W. 0. Oerloton, bolng first duly «wom, upon hla oath deposes and says: that he la Deputy Soorotary of state for the state of Wyoming, and that as such deputy he has In his possession end under his control the offloe of said Seoretary of State, ineludlng those records pertaining to foreign eorporatlona* Affiant further states that he has made a careful exeailnation of the records of said office, and that Draper & Company, fne*, a Mass­ achusetts Corporation has never filed a certified copy of Its articles of Incorporation in said office, has never appointed any agent In the stete of .Vtyoralag- upon whom service of process may be made, or in any way complied with the lava of thia state relative to foreign corpora­ tions; and that on April 15th, 1921, Paul Draper was not the agent for service for said Draper & Oompcnyi Inc., in the state of Wyoming. And further affiant sayeth not. ■'^^'’ �IN THE DXSTHICT COURT OF THE TOOTED STATES WITHIN AND FOR THE DIOTRICT OF WYOMING ROT B. MINTY, ) j Plaintiff, - VB * J i ) s DRAPER & COMPANT, INC., a Corporation, Defendant. k THE STATE OF WYOMING OOUNTT of LARAMIE F F ) : ) t I D ATI T . SS. Paul Draper, being first duly sworn acoordlng to deposes and says that ho is president of Draper & Company, Ino«, a Massachusetts Corporation, the defendant in that certain action now pending in the United States District Court for the District of Wyoming, wherein one Roy B. Minty is plaintiff; that he is familiar with the transactions and business affairs of said Draper & Company, Inc., and that he knows of his own knowledge that said corporation has not since February 11th, 1930, purchased any domestic grease wools either in the State of Wyoming or elsewhere throughout the United States; that on said February 11, 1930, said Draper & Company, Inc. entered into a contract with National Wool Marketing Corporation, by the terms of which It became exclu­ sive agent of the National Wool Marketing Corporation and ceased to do business on its own account in domestic grease wools. Affiant further states that said Draper & Company, Inc, • never had any office in the State of Wyoming or any local agent or officer in said state and that it did not have any office or any > local officer or agent in said state during the years 1930 and 1931; and that it did not transact or carry on any business of any kind In the State of Wyoming during the year 1931. ' i ' < �Affiaot further states that he was not on the 16th day of April, 1931, and never had been managing agent of said oorporation in the State of Wyoming, and that he never personally transi acted or carried on any business for and in behalf of said Draper & Company, Inc., in the State of Wyoming. Affiant further states that he has been engaged for many years in the wool business, and is thoroughly familiar with the marketing of wool; that because of his familiarity with all matters pertaining to the wool business, he was requested by the Wyoming Wool Cooperative Marketing Association, a Wyoming Corporation, to come to the State of Wyoming in the month of April, 1931, to meet with the wool growers of said state, to taUc over the wool situation with them and to explain to them the advantages of the co-operative marketing of their wool through the national Wool Marketing corpora­ tion, with which said Wyoming Wool Cooperative Marketing Association was and is affiliated; that affiant was in the City of Casper and the State of Wyoming on said 16th day of April, 1931, the day the summons and a copy of the petition in the case of Roy B. Minty vs. Draper & Company, Inc. was served upon him, at the request of said Wyomixig Wool Co-operative liarketing Association, for the above des­ cribed purposes, and for no other purpose whatsoever; that affiant was not in said city and state on said date on any business connected with Draper & Company, Inc., nor did he transact and carry on any business for said corporation while in the State of Wyoming on that date, or at any time subsequent to Kebruary 11th, 1950. Affiant further states that Roy B. Minty never represented Drapfur & Company, Inc. in the State of Wyoming, and that the placing of the name of Draper and Company, Inc., upon the door of the said ■5ttittty*s office in the Henning Hotel at Casper, Wyoming, was done wholly without the knowledge or consent of Draper and Company, Ino., or of any of its authorized officers or agents, and that all announce­ ments and advertisement by the said Minty to the effect that he was the local agent or representative of Draper & Company, Inc., in the State of Wyoming were also made and done by the said Minty without the knowledge or authorization of said Draper & Company, Ino. or of �any of its authorized officers or agents Affiant further states that his attention has been called to certain affidavits filed herein by the plaintiff to the effect that one H. H. Bennett and one W, J. Kissick had solicited cer­ tain residents of Wyoming during the year 1951 to sell their 1931 wool crop to Draper & company, and in this respect, this affiant alleges that neither the said H* H. Bennett nor the said ff. J. Kissick nor any other party had any power or authority to purchase wool or to solicit the purchase of wool in behalf of Draper & Company, Thc^, during the year X931 in the State of Wyoming or elsewhere in the United States; that Draper & company, Inc., during the year 1951 did not purchase any wool from any person in the state of Wyoming, and they did not authorize or permit any one with their consent to eollolt the purchase of wool in the state of Wyoming in their behalf, and that if any such solicitation was made by the said Bennett or by the said Kissick, it was made without the consent or authority of said Draper & Company, Inc., for the reason that since February 1930, said Draper & Company, Inc., has not purchased any grease wools, or had any agents or officers in the field for the purchase of such wools, but has acted solely as the exclusive agent of the National Wool Marketing Corporation in the sale of the wools purchased by said Corporation fr<»a the members of said affiliated state orga­ nizations, such as the Wyoming Wool Co-operative Marketing Association. And further affiant sayeth not* Subscribed and sworn to before me this 12th day of January, 1932 Notary Public �W’^V ‘ >- - W m DISTRICT COTOT Qf THS WIJTBD wrmn: " ’!?■> •*? * ^'' * * * J \ '/.Av 'i » .K- t? aio m the district or ¥ioyxm V. *' 'f 6 ‘ * t , , *■ ROT B* MIBTT, '’ ' “• ’-■* , jy’ vf A \‘‘C^ is,. ,* Sr naiAtifr* 'I • TB • 1^. mPKR COUPAKt^ XRC«t a Corporattoa^ ta ... DefB&dont. rs# A r r X 0 A T X T ;r4 1 <> 5:* St VSSyiSlS ^ oowt or tmms > CharXea X» TattXB» twine flrat <ttXr aaorn aooorAlag ta IWa upon hla oath Oopoooa and aaro that ha roBldea at Salt Latoa Oltr la tha state of Utah and 1* the vaatarn repswaantatlve of Draper & Cwapany* Iao»» and aaa In the year 1930 and for sereraX yeara prior thereto the western repreeentatlve of Draper S& CosgwnT* Xao«a the defendant in the above entitled action. Affiant further atatea that In the early part of the -wMith of-fudiqmwy la the peer 1930« the exaet date being to thia affiant unknownt affiant net the above named plaintiff* Roy B« Mlsty^ and «ie G* T« Thomson at the Brown Falaoe Hotel In the city of Denver la the State of Coloradoj that the said G. T« Thm&eon was then «id for sosietlme bad been In the eaploy of the Rational Wool iMrlcetlng Corporation and was not then and never had been la the employ of Draper Company» Inc* Affiant further states that be teows of hla own haewledaa that said Draper & company* Ino., on or about the 11th day of 4.' �Tebxuaryi 1930, entered late a oontraot with the SatlosaX Wool ;|torketing Corporatlont by the tenoa of idiioh it agreed to beoorae, did beoo2Be« the exoXuelwe sales agent of said Corporatioa* and that, after said date, said Draper & Company, Ino. did not purchase any domestio grease wools in the State of Wyoming or elsewhere in the United States of Amsrioa, but has been engaged solely in the marketing and sale of wools consigned to said National Wool Meo^etiag Corporation by the Co-Oporatire Sterket* lag Association of wool growers throughout the United states* Affiant further states that, at the time he mot with the said Minty and the said Thomson at the said Brown Palace Hotel in the month of Tebruary, 1930, the Wyoming wool Co-operatlTo Marketing Association was just getting started and that Draper n Cm^ny, Xno* was trying to assist said Association in getting organised; that affiant talked this matter over with the said ; Hoy B. Minty and explained the entire situation to the said Hintyj that he explained to the said Minty that Draper & Company, Inc. had gone out of the wool purchasing business and he made it very plain to the said Minty that he was not employing Minty for Draper & Company, Inc*, but that Draper & Company, Inc* were willing to adwanoe and would advance to the said Minty 51,000.00 as a drawing account to cower his expenses while he was employed in soliciting wool growers of the State of Wyoming to become members of said Wyoming Wool Co-Operative Marketing Association and to market their wool crops through said Association and that no other or different agree­ ment was made with said Minty, by thia affiant, as agent and representative of Draper & Company, Inc., and that the above was and is the only agreement made by any one authorised to represent Draper & Company, Inc. with said Minty during the year 1930. Affiant further states that the said lUnty was told at eaid time by this affiant and it was distinctly understood by and between affiant and the said Minty that the said 51,000.00 so to be advanced to the said Minty as a drawing account was advanced �t»y'* OMtMar* Xm* fii* Mia la tabaXf «t «m1 co«0>em%iird ll&tlEotlng AsMeiatioa axid that said aoney was to he repaid to said Draper & Oempa&yt hy eald r?yosiiiig wool OgwOperatlre liarkatlng Meoelatloa* and amm:it kneve of hie ova knowledge that said laoaoy ao adwaaeed to said Minty hy said Pcapar & Conpeny* Xnd. was a^ervards repaid to said Draper & Oeapany* Xne* by said iryomlns Wol Go«Op«ratlye iMrkatlne Asao* olatiott* And further affiant sayeth not* Suhsorll^d and sworn to hefora as thia IDth day of January* 1932* �'5*.“ '-X,'’ -'-f IK to: oiotrict court or tub toxtso otatbs w» ■• . A: AKD m m oxwRXcsT or wroJOTa '"j. .'■J' * \ BOTB. MIKTY, r JPlMAtiff* A ’i *• * i p 1 rW-.v'W.^' s?-' 'i-'- ! • - > *<5 7’A '■ • ys «• •'. ' 9 .'< • ftf ’ k 4 ? .r«’^^■'• .-3. ••j. ••> '.•'. s ' ’'’ V**5 i •, • itW*; r ’ mxn<n? a oc^k^ a CorporatlMt '*5: ’V ^‘ ‘ C \* Dqfondant. .7?. / - 7' <■ >' / v<.^^ r * i' O^-' A * ' * > r t n A r X T -As ' f -u h' WB STATS or OTimWCI GOWT OS* xm?o ’ , vf ■^. ^-w-." ' - -;k f ■ > ' . * i ‘ :SS. Charles n« Gilson* he tng first duly sworn aeeordl&g to law, U3p<m his oath aeposes ana aays that he Msldos at gWlnXey, OenweiWQ <^nty» ^mlng, and Is the 3eo2*etary->Tx*easurer of the iryoniBg ttooI co^Opentlwe Marketing Assooletlon, a oorporatleat <nrgasUi^A and oxistlhe^ tinder the laws of the state of wspaolag and <m@ased la the aarl^tln^ of wool for the wool growers of Wyoming who are or nay ho6o:«» numbers of said Assoelatlon* That he knows of his own knowledge that Draper Coo- >aayt Xnoa, the defmidast In the above entitled action, ms not yhgaeed In any business In the State of Wyoalag during the year W5a and that It had no property, or office* or plsos of buslneim in said State during said year and did not purohaae any wool la Mid state during said year* Affiant farther states that his attention has been oallM to an affidavit filed herein to the effect that one Jff. H* Bennett purchased on automobile In the City of Casper In the year 1931 and paid for the Sane by a draft upon Wpar A Company, Xno«, �• .X.' • ‘ the d«fen4aat hez<Qln} that affiant knowa of hla own knovladga that aaia oar was ths personal pxoparty of said K. n. Bennett and saa reglBtersd la his naoe la the offlee of the Saeretarjr of state for the state of Wyotalng and that the license for said oar eas Issued to said H» n. Beaastt. Afflaat further states that ha la well aegualated with H, R« Benaettt Joe Rlehards, 71b Hannon, a. T. nxMaea ot Boston, Uassaohusetta, !tt Klssleh ot Olllette, ^TyoBlng, aad Hoy R. UMte and Don A. Blrrsll of Salt Take city, Utah, end that he ■,.,-^.lBiew of his own knowledge that none of said persons were engaeed dke purchase of wool for Draper & Coipany, lao. In the State of >{i.'-I -'/Ryoiilne In the year 1931} < that raid parsons and eaoh and otory of ^WB during the year 1931 solicited certain wool growers of the Si»te of wyoBlng to heooira samihers of the S^naalae Sool co-Operatlro Marketing ^soolatlon and to aarket their wool through said Asso­ ciation, and| noting tor otA in behalf of said uyoalng wool Co- Operative Marketing Association, did eratraet to purehaae and did purahase for raid Association oertaln oropa of wool In the state of ryoBlng In the year 1931, dfflc^ak further states that said Wydfflla^ ^1 Co-Operative AssooletlMi is assoeiated with the national rfool Marketing OmpOratlra aad is a stockholder and larahor ot said corporation raieh has Its headquarters at Boston In the state of TMsraebusette) thdt It has a contract with said Corporation by the terras of which It Markets all wool purohnsotl by It throupji said National Wool Mar­ keting Corporation and pays said National Wool TSarketlng Corporation the sura of one and three-fourths (1-2) Cents per pound for such ser­ vice in the marketing of said woolj that, la addition to the mo-v-t- Ing of Bald wool under the terras of said agreeraent, raid National Wool Maiketing Corporation agreed to furnish aad did furnish to the Wpoaing Wool Oo-Oporatlvo Marketing Association experts In wool to appraise the wool crops purchased by said Association, and that In the year 1931, In aoeordance with said agreenrat, said Itetional wool �dorporatloa fUteSatoA to the wycaaine ’^ooX Co-Operatlvo llarMtt&g Assoolatl^^ the aaia B» H* Bennett, Joe niehox^, Jia llua^ T« Thoaeon, w« J. Kleelek, Hoy Isoore ana Bcm A« liirpell, as sueh exports to appraise said wool crops; that tM duties of said expez*ts were to visit each and every xaonber of said Assoolatlon to app:imlse the value of the wool crop of said rams* her as a basis of advance payments to he made to said menher* Affiant further states that, under the terms of the ooatract hetwoea the t/yomias ’^®oX Co-Operative iMrlEetlne Aasooiatlon and said mtionol wool mrhetlng Corporation, said KatlonaX wool liar^tlng Corporation agreed to adimnoe to the msmhers &t the Mid Timing Assoolatlon, prior to the sale of their wool, a cer­ tain percent of the value of said wool crop, and that these experts ahei^ mentlimed detemlned Mt only the value of sold wool crops hut the percentage of said value which should he advanced to each member of said assoeiatloai that, fbr this purpose, each of the above naatd piurtleB were appointed Assistant Seorotarles of sold Wyoming weoX Go-Opcratlve Mairketlng Association and were authorised to draw drafts, and did draw drafts, iwon said l^tlonal Wool iSarMt* lag Corporation la favor of said grower member for the amount to he advanced to said tEBmber upon his wool crop and said drafts were paid by said national Wool yarheting corporation and ciinrged by it to the aoMunt of the WyoMng Wool Co-Operative Wrketlng Association, who In turn charged the same to the individual account of the n»cfl>or the Assoolatlon otmlng said wool crop. Affiant furUier statos that during the year 1931, as Seoretary*"Treasurer of said Wyoming Wool Co-Operative Marketing Association, he worked with each and all of the above named expertsg that It was his duty to notify them when and where to go to qppraise wool crops, and that he knows of his own knowledge that each and every of tlui above statezwents are true. 1 Subscribed and sworn to before me this IJth day of January, A< D. 1932. Notary Puhlloy -------- �IS THB OTITBD STATES DISTRICT COURT FOR TBE DISTRICT OP WIOKIHO « ROY B. MISTY, « e ■ 3 Plaintiff, } ) V8. DRAPER & COMPANY, ISC., a Corporation, Defendant* Civil So. 2107 Deposition of sundry witnesses taken before me,Madge R. mxlte, a Hotery Publie within and for the County of Natrona, State of Wyoming, on the 12th day of January, 1932, between the hours of 9 o’olook A.M. and 5 o’clock P.M., at 309*11 Consolidated Royalty Building, Casper, Wyoming, pursuant to agreement, to be read in evidence In behalf of plaintiff, in an action ponding in the United States District Court? for the District of VS^oming, in which Roy B. Minty Is plaintiff, and Draper & Company, In©., a Corporation, is defendant. John P. Nolan, of lawful age, being by me first duly examined, cautioned, and solemnly sworn as hereinafter certified deposeth and s aye th as follows, viz: Q. State your naise* A. John P. Nolan. Q« What is your occupation. At Automobile dealer. Qt With what automobile company are you associated? A, Solan Chevrolet Company, Casper. Q» What, if any, position do you hold with the Nolan Chevrolet Co^any? At Secretary, Treasurer, and General Manager* Q. Were you such Secretary, Treasurer and General Manager during the year 1931? A. I was. Q. During the year 1931 did you know one H. H. Bennett? A. I did. �Q. Did you have any buelneea dealings vlth Mr. BennettT A« Tes, I did. Q* Will yon state what they were? A. Oh the 17th day of April, 1951 Hr. Bennett purOhSsed a Chevrolet automobile from me. • *. * ‘ Q. Bov was the oar paid for, Mr. Molan? A. The car wae paid for with, or by, a draft on Draper & Company. Q« That*a at Boston, BaasachusettsT A. I don't remember whether "Boston, ttaseaohusetta" appeared on the draft or not • Q. Was the draft paid? A. Yes. �Arthur Faaailaro, of lawfixl ago, being by me first duly examined, cautioned, end solemnly svom &s hereinafter eertlfled, depose th and sayeth ae follows, vlsi Q. Will you state your nsme? A» Arthur Fasmlaro. Q. Tour occupation? A. Clerk. Q. By tAiom are you en^loyed? A. Henning Hotel. Q. Were you clerk In the employ of the Henning Hotel during ths year 1931? A. Tes, sir. Q. Are you acquainted with one H, H. Bennett? A« Tea, sir. Q, Were you aoqxialnted with him during the year 1931? A. Tes, sir. Q. You may state. If you know. If Rr. Bennett stayed at the Hennlztg Hotel during the year 1931. A* Tee, air. Q« Do you know for how long a period of time? A. I can’t say for sure. Q. Approximately? A. Between two and three months. Q. During what months of 1931 would that be? A. I know he was there In June, but I can’t say Just how long he was there. It might not have been two months. Q. During the time that Mr. Bennett stayed at the Henning Hotel In Casper how did he pay his hotel bill? A. well, he paid hie bill la cash, but he Gashed some drafts. Q. Have you any record of any drafts he was at the Henning Hotel? A« Tea, sir. Q, What record do you have? A. On, our date, of June 8, 1931 there was draft drawn by H. R. Bennett, payable to the Hotel, on Draper & Company, Boston, for $200,00• Mr. Bennett cashed while �Q. a« Q. Do you have any pooord of any other draft? There waa one on, our date, of June 19th, H« B« Bennett payable to the Hotel, on Draper & Company, Boston, for 1800.00. Do you have any other record? There was one on our date of June 50, 1951, H. H. Bennett payable to the Hotel drawn on Draper A Boston, for #160.00. A. Q. How, you Bay that this money was need to pay hie hotel bill with? A. How that I oan't say for s^ire » can’t say that It was used for the Hotel - might have got cash for it and not have paid the hotel. �STA'fE OF V.YOMHO, ) t SB. COWn OF MATROKA. ) I, MadgB R. VShlte, Rotary Public in and for said oounty and atata, do hereby oartlfy that John P. Rolan Arthur Fawilare «• • severally duly aworn to testify to the truths the <iole truth end nothing hut the truth* end thet the depositions, by them respeetlvely suhsorlbed es ehOTS set forth, were redueed to writing by myself, end were respeotlvely suhsorlbed by Uxe seld witnesses In my presence, end were teken at the time and place agreed upon} thet I am not counsel, attorney or relative of either party, or otherwise interested in the event of thia suit} end said depositions were commenced at the time specified. In Testimony whereof I have hereunto set my hand end seel this 12th day of January, 1932a My commission expires July 28, 1933. ?■ �STATE OF wrcarato, > ■ I aa. ' y j/ cowry OP MATRONA. ) X> Madge K, White* a Notary Public In and for said county and state, do hereby certify that John P. Nolan Arthur Famularo » first severally duly sworn to testify to the truth, the whole truth and nothing but the truth, and that the depositions, by them respectively subscribed as above sot forth, were reduced to writing by nyself, and wex*e respectively subscribed by the said witnesses In wy presence, and were taken at the tine and place agreed upon) that X an not counsel, attorney or relative of either party, or otherwise Interested In the event of this suit} and said depositions were eoBBieneed at the tlxse specified. Xn Testimony whereof X have hereunto set my hand and seal this 12th day of January, 1932. Ky commission expires July 25, 1955. �That later I Introduced Mr. Scherck to Mr. Draper and Mr. Scherck, in discussing the matter with Mr. Draper, explained that, according to figures, there was a great discrepancy in the weights as submitted from his office with reference to the amount of wool Draper and Company were holding, which belonged to Scherck. Mr. Draper said; ”1 am very sorry that this has occurred and am not in position to discuss it in detail now, but If you will write a letter and address it to me in Boston, I will take the matter up on my return to the office and render you statement to date." Immediately after his conversation with Mr. Scherck, Mr.Draper said he was leaving for Douglas and expected to arrive in Denver that afternoon. �That on or about April 15th» 1951 Thomas Cooper, President of the Wyoming Woolgrowers Association, cams into my office in the Henning Hotel, where he remained over an hour, during which time we discussed in a general way, woolgrowers and woolgi‘owers organizations. He Informed me that Mr. Paul Draper, President of the Draper and Company, inc., wool merchants of Boston, Massachusetts, and sales agents for all wools consigned to the various cooperative organizations under Government control, was expected to arrive Casper that afternoon, and that he. Cooper, was making every effort to get as many woolgrowers together as possible for a meeting that night at the Henning Hotel a»d Mr. Draper was making a tour of the state for the purpose of explaining cooperative marketing to the growers and to induce them to consign their wool to the Wyoming Cooperative Marketing Association, for v'hich Draper and Company, Inc., as above stated, were selling agents. That Mr. Draper did arrive as expected, and did hold meeting in the Henning Hotel that night as planned, at which meeting certain woolgrowers and bankers were present. Up to the time of Mr. Draper’s arrival in Casper, he had visited several towns on the U.P., Lander, Worland and Thermopolis. The day following his arrival in Casper, he drove to Buffalo where he held another meeting, returning to Casper late in the after­ noon of the same day. The following morning, Mr. Frank Scherck, local wool grower, came to my office asking if I had seen or if I knew Mr. Draper; that he was anxious to meet him and if possible straighten out a tangle in weights and figures of a clip of wool Mr. Scherck had shipped the previous year, and of which Draper and Company, Inc., were In possession. ��0 IB THE UNITED STATES DISTRICT COURT FOR m DISTRICT OF TCOMIBC • • ROT B. WIHTr, Flftlatlff, Auto & coa?A>n^ a Gopporatioa* *, . V"..7 Defendant. ) Civil Ho. 2X07 1 ‘. STATS GF WXOBIHQ, } t at. COOTTT OF BATm>BA. ) AFFIDAVIT B« IU.BtF, Qt lawful age. and being first dulx awom. upon oath depoaea and aaya: That he 18 the plaintiff xuomd In the above and foregoing entitled eauae, and, in addition to the oral teatlm<»^ heretofore Introduoed by hl», makes and files this, his affidavit} That he Is veil aoqualnted with one Thomas Cooper, and has been for some years last past} that during the year 1931 said Thomas Cooper was President of the Wyoming Woolgrowers* Association; That, on or about the 15th day of April, 1951, your affiant was advised by said Thomas Cooper that Paul Draper, President of Draper & Company, Inc., wool merchants of Boston, Massachusetts, expected to arrive In G.sper that afternoon for the purpose of Influencing wool growers In aborning to market their wool tiu'ough the various cooperative marketing associations. Including the Hatlonal Wool Cooperative Martcat Ing Asaoeiatlon, for which said l>aper Ic CcnapaxQT were exclusive sales agents; That said Draper did arrive In Gasper on or about said 15th day of April, 1931, and held a meeting that night at the Henning Hotel in Casper with various wool growers In Hatrona County; That, prior to hla arrival In Casper, the said Draper had �visited several teens along the TTnloa Pselflo Hsllresd, had visited in Xander, Worland, and Themopolla, all being town In Wyoming* that the day folloelag his arrival In Casper the eaid Draper drove to Buffalo, Wyoming, ehere ho held a similar rneetlng, returning to Casper late th® same aftemoon* That the purpose of the visit to Wyoming of th© said Paul Draper was to Influonoe wool growers In l^cmslng to market their aool through a cooperative plan, and thus stimulate the huslness of said Draper & Company; That, while in Casper, the said Paul Draper conversed with Frank Soherok, a loeal woolgrower, ooneemlng a diserepaney in certain weights of wool theretofore shipped hy the said Scherek and th«ci being handled hy Draper a Co&q;>any, and said Seherck was advised hy the said Paul Draper to write the said Draper oonoemlng the matter fully, at his offloe in Boston, so that upon his return to Boston he would have aeoess to the records of the company concerning this shi^ent of wool. r-i 7 < Ti-Tt- ■■■-.■ Suhsorlhed and swem to hefore me this -—mrt I-;- - -.-ni - . day of iSranuax^, 19S8» tel:ary jPuS^^ i eemmission expires ^hly 8S, 1955. : : ' �IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF V/YOMING ■» ROY B. MNTY, Plaintiff, vs. DRAPER &COMPANY, INC., a Corporation, Defendant. STATE OF VJYOMING, COUNTY OF NATRONA. * * ) ) ) ) ) ) ) ) ) !SS. ) Civil No. 2107 affidavit THOMAS COOPER, of lawful age and being first duly sworn, on oath deposes and says: That he is a citizen and resident of Natrona County, Wyo­ ming, and has been for several years last past; That he Is at present President of the Wyoming Woolgrowers’ Association; That during the years 1930 and 1931 he was acquainted with one H. H. Bennett, reputed to be a representative of Draper & Company, of Boston, Massachusetts; That during said year 1931 he did not sell his wool clip, but consigned the same to the Wyoming Wool Cooperative Marketing Association; that subsequent to said consignment the said H, H. Bennett tested and graded the wool belonging to your affiant, after which the said H. H. Bennett delivered to your affiant a draft cover­ ing advance payment for his wool so consigned; Your affiant does not know how long the said H. H. Bennett was in Wyoming during the wool buying season of 1931, but does know that he contacted woolgrowers other than your affiant and tested and graded the wool of growers other than yoxxr affiant. Further affiant sayeth not. Subscribed and sworn to before me this My commission expires July 25, 1933. day of January, 1932. Notary Public. �IM THE UMITED STATES DISTRICT COTOT FOR THE DISTRICT OF HYOMIMG « * « ROy 0. KMTt, Plaintiff, V8. DRAPER & COUPAMT, IMC., a Corporation, Defendant. ) Clwll >O. 8107 STATE OP WOMIHQ, ) } ea. COOTTT OP MATROMA. ) A??IS 2IS THOMAS COOPim, of lawful age end being flrat duly eworn, OB oath depoaea and aayat That he la a cltlaen aad realdent of Katrona County, Myo- Bing, and haa been for aeveral years last past} That he ie at preaent Preeldent of the Wyoalng Woolgrowere* Aaaoolatlon) That during the years 19SO and 19S1 he wee acquainted with one H« H. Bennett, reputed to be a representative of Draper A Company, of Boston, Massachusetts| That during said year 1©31 he did not sell his wool clip, hut consigned the same to the Wyoming Wool Cooperative Marketing Association; that subsequent to said consignment the said H. H- Bennett tested and graded the wool belonging to your affiant, after which the said H. H. Bennett delivered to your affiant a draft cover­ ing advance payment for his wool so consigned; Your affiant does not know how long the said H* H. Bennett was In Wyoming during the wool buying season of 1631, but does know that he contacted woolgrowers other than your affiant and tested and graded the wool of growers other than your affiant. Further affiant sayeth not. Subscribed and sworn to before me this My commission expires July 26, 1935. __ day of January, 1838. Rotary Public. �XV THS UVITED STATES DISTRICT COW FOR Tas DISTRICT OF W70VXV0 » « « ROY Q. VXVTY, Plaintiff, DRAPSH & COMPAHY, XVC., a Corporation^ Z>of endant* STATS OF VYOMXSa, } s •«. COnVTT OF VATROVA. ) Olrll Vo* 0107 AFFIDAVIT WM >«•« «IIM MB* ••• TBOMAS COOPSR, et lawful age and being flrat duly awom* on oath depeaea and aaxay That he la a eltlaen and realdent of Satrona County, alx^;, and haa been for several years last paat| That he la at present President of the m^oailag Voolgrowera* Association) That during the years 1930 and 1931 he vas acquainted with one H« H. Beimett, reputed to be a representative of Draper & CoR^any, of Bostem, Vassaehuaetts) That during said year 1031 he did not sell hl a wool clip, but oonalgned the same to the Wyoming Wool Cooperative Xarketlng Assoelatloni that subsequent to said eonalgnment the said H« H. Bennett tested and graded the wool belonging to your affiant, after which the said H. H* Bennett delivered to your affiant a draft cover­ ing advance payment for his wool so eonslgned) Your affiant does not know ho* long the said B* H. Bennett was In Wyoming during the wool buying season of 1931, but does know that he contacted woolgrovers other than your affiant and tested and graded the wool of growers other than your affiant. Further affiant sayeth not. Subserlbed and sworn to before ise this My coBBnlssloa expires July 26, 1056. . day of January, 1982. Votary Public. �in THE UNITED STATES DISTRICT COURT OP THE STATE OP WYOMING R. B. MINTT, VS ) ) Plaintiff ) ) ) ) ) DRAPER AND COMPANY, Ino., a corporation ) ) ) Defendant ) STATE OF WYOMING County of Natrona CIVIL CASE #2107 AFFIDAVIT ) I SB ) Pearl B. Burna, of lawful age and being first duly sworn, on oath depoeee and aays: That she la a Public Stenographer, and was auoh Public Stenographer during the years 1930 and 1931, with her office and place of business located In the Henning Hotel In the city of Casper, Natrona County, Wyoming. That during the years 1950 and 1931, she was acquainted with one He H. Bennett; that during said years 1930 and 1931, at the request of said H. H. Bennett, she performed services for him In her capacity as Public Stenographer, and on numerous occasions, at his request and at his dictation, wrote letters to Draper and Com­ pany, Inc,, Wool Merchants of Boston, Massachusetts, concerning ac­ tivities of the said H. H. Bennett for Draper and Company, Inc., in Wyoming. That such communications concerned Inspection and appraisals of wool, soliciting of wool, advice as to woolgrowers already contacted and to be contacted and asking for Instructions as to how to proceed in certain instances, etc.. When such letters wel^ transcribed by her, they were delivered by her, personally, to Mr. Bennett, for mailing. me this 22nd day of January, A.D. 1934. �II TBS UUTKD STATES DXSTHICT COURT FOR THS DISTRICT OF WrOMW ♦ • * sot S« KIBTr> Plaintiff, vs. IffiAPER as COMPAIX, IRC., a Corporation, ) } Dtfandaat. ) STATS OP WYOMING, cotnmr of batroba. ) : ) Civil No. 2107 A F F I £ A V 1 £ Salary Mahonay, of lawful ago, and being first duly sworn, ox^ath dope BO a and sayst That ho Is a eitlson and resident of the City of Casper, Natrona County, Wytnalng, and has been for som tins last past) That, during th© year 1931, ho was ottployod by The Boa Agonoy, Ine., a li^oalng corporation, as an agent solloltlng the sale of insurance of various kindsj That he is acquainted with one H. H. Bonnett, and was during the year 1951j That, as such agent for said The Bon Company, Ino., ho sold to said H. H. Bonnett a policy of Insurance covering public liability, property dazsage, fire and theft upon one certain Chevrolet Coach, and that the presdum for said Insuranoe was paid for by said H« H. Bennett by a draft drawn, to the best of his knowledge and rooolloctlon, upon Driqper Bs Coaq^ax^*, of Boston, Massachusetts. Further deponent sayeth not. (Signed) BARRY MAHONEY Subscribed and sworn to before »e this Sth day of January, 199S. My ownmlsslon «xplr.« Madge R. JMXy 86, 1953. (SEAL) Sot.i7 biblie. �I» THE UHITKn STATES DlSTSffGt DISTRICT GF WTOKTSG FOK ■» # » ) W S* »ITOf, PlalBtlff, v«. BRAPSR at OGISFASt, XITO., a GarporatlcMft, ) Dafendant* } sm« OF irtoiiw, ) r«i* . . V"• ■*'«'/. 'V' .■> .*■.■ * Clvli 80e 81€^ AF£i£A VI £ COOTW OF SATROSA. ) Barry Sahoney, &t iK^ial and lialng flrot duly arorn, ox|bath deposes and says: That he Is a eitlsen and resident of the Olty of 0ai8p«f, jBtrona Gonaty, wymdag* and has bee» for oom time last pasti That, during the year 1931, he was araplcyed by Ihe Son Agency, Ina*, a Wyoming corporation, as an agent soliciting the sale of Insaranoe of various feladsj %at he la acquainted with one S» H, Bennett, and was during the year IPSlf That, as such agent for said The Son Company, lao-, he sold to said H. H« Bennett a policy of Inimranoe covering public liability, property damage, fire and theft np<m one certain Chevrolet Coach, and that the premium for said Insurance was paid for by said H. H. Bennett by a draft drawn, to the best of hl a knowledge and reoolleotlcm, up<m Draper & Oompaay> Boston, Massachusetts. Further deponent sayeth not* (Signed) BARRY MAHQHEY Subserlbed and sworn te before me this Sth day of Fanuai^, My oomwlsslon expires jily 2S, IWSS. (SEAL) ioiary pSafo. �tH THS DISTRICT COURT EIGHTH JUDICIAL DISTRICT WB, Mim, ) * ▼8 * ) mPER & COMTAHT, IHG», j a Corporation, . . | J ' Dafoad^t..) . owMsajroR movAX " . < ■ J;.-<^3 .‘^•Z THIS anttor eoaing oa reguleriy tiaard ajioft tha petition and bond of the defendant heroin for an order transferring this oauee to the United States District Court for the District of ■ <'* Wyoming:, and It appearing to the Court tlwit the defendant has filed ’ its petition for such removal in due form of las and within the time provided by statute, and that the defendant has also filed his bond duly conditioned, with good and sufficient sureties, as pro­ vided by law, and that defendant has given plaintiff due and legal notice thereof; and It appearing to the Court Wat this Is a pro* per cause for removal to said Dlstriot Court of We United states; MOW, THSIWOB?, said petition and bond are hereby accepted and, XT IS roteT GRDEW AHD ADJUDcm> that this o«ise be, and it hereby Is, removed to the United States District Court for the Dis­ trict of Wyoming pursuant to the statutes of the United States In such case made and provided, and that all further proceedings in this Court be stayed, and that the Clerk of this Court, be, and he hereby > V Is, directed to make up a transcript of the record In said cause for tranaialsslon to said United States District Court forthwith* Done in open court this j day of May, 1931. �THS STATE 0» WeMBIO ) J3S. COUSITY 0? ) IN THS DISTRICT COURT KOHTS lUDICIAI DISTRICT : aoTB.MirrT, : . . Plaintiffi * vs * DHAP3R a CCMFAMT, XNC., a Corporation, X>efe&dant« .?9TXTX<» m oaos^ » Hwrics if • • , ’ «i , • • • « * • r• . rok^ax.. '' . I?• * •’*4 * • • r* • ,■ ■. ', •-• • • Li.-- • ■K '.*•'■ ; To the above naned plaintiff* Boy B« X&htyf and to Durbaa a BaoheXlert his attorneys of record: You and each of you will pXeaae take notice that on Satur­ day, the 9th day of May« A« D. 1931, at the hour of 10 o’clock a. M« of said day* the above naaed defendant, Draper a Company, Xno«, a Gorporatlon, vlll file In the above named court Its petition and bond as required by law for the removal of said cause from the above entitled court to the united states District Court for the District of Wyoming, and will at the sama time, or as soon thereafter as coun­ sel can be heard, move the court for an order removing said cause to the District Court of the United States for the District of 'Wyoming, In accordance with the petition and bond of defendant, copies of which are hereto attached. Dated this day May, A. D. IWl* > XttornB^ for Defeadan t. . ..■lb hereby acknowledge receipt of a copy of the above notice, also of a copy of the petition and bond for removal this ^\^. day ot Jtoy, IWI. i Attorneysr?orPlain tiff �THS 3TAT2 07 WTOMISO) :sa, GOOTTr 07 lUTWA ' 1 Ur ras DISTRICT COURT RXtWS JUDICIAL MSTRICT TOT B> MUPTT, Plaintiff. ■ * ▼«' * ■ DIUP2R & COKPAKY. IHC., a Ooxporatlon. r DefaMant.) PSTITIOR 70R R3TOVAL TO THS 7SDSRAL COURT. the Honorabla. the Diatrlot Court of the Sighth Judicial Dietriot, sitting vlthln and for the County of Natrona, in the State df wyottlngi The petition of Draper & Company. Ino*. t3xe above nazaed de* fondant, appearing herein speoially and for the purpose of thia re* jeooral alone. rei^eotfuUy repreaenta: 1. That the above entitled aotlon has been brought in thia Court and la ao« pending heroin; and that the tlras within which defen* dent la required to answer or otherwise plead has not yet expired. 2. That said aotlon la of a civil nature; that plaintiff In his petition alleges that on February 4. 1930, he entered Into a contract with defend ant, by the terns of whloh defendant mployed him to pur* ohase wool for defendant In the State of ^yonlng. and that plaintiff was to receive one-fourth oent per pound for all wool so purchased; that duzlng the 1930 season, he purchased 4,698.673 pounds of wool, and also paid out in filing fees the «im of $4&0.C0} and that defen* dant had paid plaintiff only $6.saQ.22, leaving a balanoe due plain* tlff under the tenss and conditions of said oontract in the sum of $8.&93.4d. for which, together with Interest thereon, plaintiff asks Judgment against defendant* *1* f �3» That tha valoa of the matter la oontioveray between plaintiff and defendant In said action la xaore than three thousand dollars, 4* states; That this suit la wholly between citizens of different that at the tlxEie when said suit Instituted> and at the present time* the plaintiff was and Is a eltlaen and resident of -tihe State of Wyoming; and that the defendant* your petitioner* was and Is a corporation organized and existing under and by virtue of the laws of the State of Uassachusetta* having Its prlnolpal office and plaoe of business In the City of Boston in said state* and was and Is a resident and eltizen of said State of Kassaohueetts. 5. That your petitioner presents herewith a good and suffiolent bond* as provided by the statutes In such oases* condl* tloned that It will enter In the Dlstrlot Court of the United States for the District of Jyoralng, within thirty days frcQ the date of the filing of this petition* a certified copy of the reeord In this suit* and that it will pay all coats which may be awarded by the said Die­ triot Court* In case the said court shall hold that this suit was wrongfully or improperly removed thereto* WHEH3F0RK, your petitioner respsetfully prays that this Court proceed no further herein* exoept to make an order accepting the bond presented herewith and dlreotlng that a transcript of the reeord herein be made for filing In the United states District Court aforesaid* Xfto'iSey 'for Braper 4 Gtwg^y * Itnc TBS STATS car W COWTT oy LARAJCS :5S. ) lU A* Kline* being first duly sworn* on oath says that he Is attorney for Draper & CoaQ;>any* Inc** who makes the above and fore* going petition for removal; that he has read said petition and verily believes that the statements therein contained are true; : that he makes this verification for and In behalf of said petitioner for the reason that said petitioner Is a foreign corporation and Is not a reel* �subQorlbed and awora to before m thl* , day of �m STOT 0? WTOtfW) h iSSe' cotsm-or si’wm f I» TBS DXSTHIOT oom " SIOSTH JDDICK larsi^icT ROT B KBrar PlaintiffJ ▼8 COKPABT, IMG., a Ooi^osratiM, ^WSR '. * « Defendant. T-- •a ’ <> ;^ra OR RsiKnrAX. ■i' L^'WOS AlX JC^‘St-RISSB PH3SOTS^, That we. Draper & CoBQjany Iqo a eorporatioa, and the JSassaohusetto Bonding * Insurance Coa- paay. & oorporation duly organised and existing under the laws of the State of Kassachuaetts, and being duly authorized to transact and carry on business as a surety company in the State of Syomlng, are held and firmly bound to Boy B. Kinty, the plaintiff in the aboTe entitled cause, his successors and assigns, in the sum of yive Hun­ dred (1500.00) Dollars, lawful money of the •Onltod states of America, for the payment of which, well and truly to ba made, wo and each of as bind ourselves, our suceessors and assigns. Jointly and severally by these presents. SaShSAS, the said Draper S; Company, Ino., intends to file in the District Court of Natrona County, Wyoming, its petition for the removal of a certain cause therein pending, wherein Hoy B. Minty is plaintiff, sad Draper & Company, Ino., a corporation, is defen­ dant, to the District Court of the Halted Statee » for the Blstrlot of ‘ Wyoming for fta*ther proceedings oh grounds in said petltKm «t forth and asking for a stay of all further prooeedinge In said District Court of Ratroaa Couoty, wyosiogj �IBSHEFCHB, the conditions of this obligation are such that if eaid petitioner, Draper ac Coi^any, Ino., shall enter in said District Court of the United states for the District of Vyomlag, within thirty days from the date of filing said petition* a certi­ fied copy of the record in said suit, and shall pay, or cause to be paid all costs that stay be awarded therein by said District Court of the United States, if said Court shall hold that said suit was wrongfully or improperly rexaoved thereto, tl^n this obligation shall be woid; otherwise it shall remain in full force and effect. Dated this day of May, JL. D, 1031. �IK THE UNITED STATES DXSTRIOT COW THE DISTRICT OP wyoMim ROY B. KIHTT, | draper > COMPAKT, IHC., ) i Defendant* } MOT X C B TO Ws ABOVE BAMED AND TO Hi A. KUKE, ITS ATT(Wsy OT and ea<^ of you will ^leaee taXe notice that the above named plaintiff will eall tg? for hearing and determination your 8O-oalled motion and apeolal aj^earen^ filed herein before ’O” !'■ ■■ '- -■ W^taesdi^^ the 10th day /. the/.all^ln^' i<Ch»y»nne>-^^^ if Ifl^i; at 10 b^olifel? in the forenoon, at >dil<^ time and place you »y he prc^eent If you 80 ^alre< i Ati;orne;i^\ ?or YiSnHff Reoelpt of the above and fore golnc Sotlee la hereby aokno^dedged thia 1931, •L-J/ Attorney for liefendant - % <7* ■s* '' "'■O' -v 'r- * > '..'••ft' ■'» > '^' A ■*’•■)> K * * • # * « �i« ttt msTracT ccayRT or "ifiTHiii kjtri ro« ths nams statks th€ msmct ca^ wroMimJ ••**•«••»•«••« KOT 3. UTKTT, Plaintiff^ -va- < COMPAWT, T»C,, D»f«odaat» ' '•? BP8CTAL APmnAKC< AM COTXOB TO QUA^J Com* bo« We nasetf defesdast^ Oraper and Coapany, Tnc., and appearji^ epeclsily Tor Wa purpose of objecting to We jurisdiction of tMe eowrt ©eer We persoe Qt Wls defendant, and for no other purpose n&atsoerer, Movee We Court for on order quashli^ and eettlng aside the service of suMons and the saerlff*e return of eervloe «ada la the above entitled ustter, and as grounds of said taction, defendant respectfully shove to the Court aa folloes; 1, That the defendant Is a foreign corporation, duly organist and eilsting under and by virtue of the laee of the State of Sasssohueetts, with Ite head^i^artere and prlnclj^l place of bus­ iness In We City of Boston In said state. That the defendant on We 13W day of Aprils A« D, 1931, we day wen said purported ecrrlce of mMwons was attempted to be mde utx>n Wls defendant, vas net traneaotlng any business of any kind In the State of ^yo»ln^ and did not have any agent, office, or place of business In said etJ^te, nor had defendant transacted any business, or had any agent, office, or pl^e of business In the state of Wyoming, for a long time prior to said April Idth, 1931. 3. That Feul Prsper, We person upwi Worn We protended service of saaBnone »a« »ada^ eas not on said April IS, 3531, and �never had been an agent oT the defendant In the State of Wyoaingj that on said date the said Paul Draper was not the managing agent of said defendant In the State of Wyoming; and that he was in the State of Wyoming and In the City of Casper merely as a visitor and attendant at a meeting of the Wyoming Wool Growers Asaocletlon and not as an agent or officer of defendant corporation, or on any bue- iness connected with defendant corporation. 4. That eaoh and all of these matters are more fully shown by the flies of this case, and fey the affidavits of Paul Draper, Joseph P. Draper and Paul W. Brown annexed hereto and made a part of this motion. �Ttia State of nontnnu ) Cottsty of ) Paul DT*o«r, ^etag fUxst tely awora aowrdlng to law, O^K)se« and eaya that ha la aaaatdaat of nf*»oar A Coapany, Inc., a Maaaaohuaatta Corporatlon, idia dafandaot In ttoat oaxtsln action now ponding In the United Statea matriot Court for tha Diatrlct of ayoiBiftgi i^ardln ono ^oy 8. Minty Is plaintiff} that ho Is faalllar with ^a tranaaotlona aial taialnoso affairs of said Dtapor £ GoBpany, Xnc., and that ha knows of hl a own knowledge that said corporation has not olaeo fohruftry 11th, 1S30, puroheesd any doBoa110 gr^o wools either la «io StnU of wyoaing or alse^iiaro throtudiout United ^^taa| that os said Fehruary 11, 1930, said Draper & Odbpat^, Inc. entered Into a contract with Rational Sool Marketing Corporation, hy the tome of which it booaae exolusivo agent of Rational itool birkotlhg Corporation and ceased to do business on Its own aooount in doseetlo grease wools. Affiant further states that said Draper A Conpaay, Inc. newer had any office in the state of Rowing or any local agent or officer In said state and that It did not have any office or any local officer or agent In said state during the years 1930 and 1931} Affiant further states that he was not on the 13th day of April, 1931, and newer had been managing agent of said corporation «•**< peraoaally trsns^-ctsd In the state of or carried on any huslness tot and In behalf of said Draper A Coapan]^ Inc., In the State of Wyoalng. Affiant further states that he has heea engaged for naay years in the wool business, and Is thoro'ih^hly feMllar with the aarketli^ of wool} that because of his faalllarlty with all natters pertaining to the wool business, he was requested by the wyonlng Dpoperotlwe Marketing Association, a doming Oorporatlon, to �OOM to the state of ifyoming In the Month of April, 1931, to oeet with the wool growors of m1< oteto, to lolk over tho wool situation with thSM sad to osplain to tho» tho adwantagos of tho oo-opor&tiTo narhatlr^ of thslr wool ti&rough tho Satlonal wool iiaricatiag Corpor*tlon, with which said wrowlag Mol CooM»ttwo ttnzhoting AaaooiaUoa was and is affillatedj that affiant wag in tho City of Cagpox* tho Stato of Wyoming on said 16th day of April 1931, tho day ths suauBone and a copy of tho petition in tho oage of Roy 9. Minty vs. Draper A Company, ino. was eexwed upon him, st tho roquoet Qt said owing Wool Co*oporativs Saidcetli^ Assoolatlon, for the above dee- soribed purpoees, and for no other purpose whateoevoTi that affiant was not in said city and state os said date on any business oonneoted with Draper A Cowpany, Inc., nor did he trasMot and carry on any business for said oorporation while in the State of Vyoaiag. And further affiant sayeUt not. ^bsorlbed and owom to before m this 1931. sotSrf^?idstic7 day of fane, �District Court for the District fif i^omin^ In the Case of HOY B. MINTY - PLAINTIFF vs DRAPER & COMPASY. IKCOHPOrvATKD - DEFEHDAiiT. A F £1£A V IX I, JOSEPH DRAPER, of Caston In the County of Norfolk and Comffionwealth of Uaeeaonusetts, on oath depose and say: (1) Tnat Draper A Company, Incorporated, la a corporation organized under tne la«s of the Commonwealth of Sassachusette; (2) That I a® the duly elected and qualified treasurer of the said corporation, which position I have occupied since December 15, 1921, and that I am familiar with the business and affairs of the said corporation; (3) That the said Draper A Company, Incorporated, until December, 1929, conducted a wool merchandising business, with offices at 281 Summer Street, Boston, MaseachuBetts, in pursuance of which it dealt In a substantial way in wools produced in the Vnlted States, buying from Western growers, preparing the wools for sale and selling the same to Eastern mills and other buyers; (4) That since December, 1929, Draper A Company, Incor- porated, has done no domestic grease wool business on Its own account but has represented the national rool Marketing Corporation In the sale of wools consigned to the last-mentioned corporation by the woolgrowers♦ co-operative organizations throughout the United States; (5) That In its contract with the said National Wool Marketing Corporation, the said Draper & Company, Incorporated, agreed to conduct no business in domestic grease wools; (6) That the said Draper A Company, Incorporated, hao never had a place of buolness or office in the State of Wyoming; (7) that the said Draper A Company, Incorporated, prior to August, 1929, occaBlonally bought wools In the State of Wyoming, �which wools were always bought for immediate shipment East and were actually shipped at once out of the State of Wyoming end not otherwise handled, sold or dealt in until thereafter; (8) That since August, 1329, Draper & Company, Incorpor­ ated, has done no business of any nature on its own account in the State of Wyoming; (9) That at no time has Draper & Company, Incorporated* conducted regularly any business in the State of Wyoming, its only business activixies there at any time being the purchase of wools at rare intervals as described in the preceding paragraphs; (10) That on the sixteenth day of April* 1931, when the purported service of summons was attempted to be wade upon the said Draper & Company, Incorporated, th© said corporation had not since August, 1929, transacted any business of any nature on its own account in the State of Wyoming; (11) That Paul A. Draper, the person upon the pre­ tended service of suaiwne was omde in this case, was not at ths time acting as agent of the defendant in the State of Wyoming but was a visitor In said Staxe on the invitation of the wyoodng 'fool Growers Association to attend their annual convention. IS WXTMSSS SBSHEOF, I, the said Joseph P. Draper, being duly sworn, hereunto set my name this thirteenth day of June, 1931. Suffolk, 88» June 13, 1931. On the thirteenth day of June, 1931, appeared tn© above named Joseph ?. Draper, personally known to me, and made oath that the statements contained in Uie aoove affidavit, by him subscribed. are true. Before me. Notary Public. �2. li'i's-D iI4112 O Z- A MZ i i'Z A District Court . District of Wyoming . ■' in the Case of _,;RCY B.. MINTY - PLAIKTIKF vs. DBAPSR company; INCORPORATED - DEFIiJNDAN.T- ,■ >. AZZISAIiI - ■■ r,':^CHOE Wi BRO^ of Boston in the County'Of ' Suf folk and Sommonweaith of agtssachusetts, on oathT depose and/say; That Draper & Company,;IncofporatecL,\is a corporation " organized under the laws of the Commonwealth of Massachusetts; (3) -That 1 »aa-aadl JafiT© Peen since Decemher 15^^ 1921, . the duly elected and qualified clerk and assistant trdasufer of the, said Draper & Company, Incorporated, and that I am familiar with the business and affairs of said corporation; (3) That the said Draper. & Company, Incorporated, until December, 1929j-, conducted'a wool merchandising business, with offices ■. at 281 Summer Street, Boston, Massachusetts, in pursuance of xvhich'it"" ’■ ■" ■ dealt in a substantial way in W'ools produced in the United States, buying from. Western growers, prep.arihg the: wools for sale and selling the same to Eastern mills and other buyers;. ; '(4) That^ ■since' December., 1929, Draper A Company, Incorpor* , * ated, has done bo doiaest-i<<^^easeiwoi business -on rite - own .account but has represehted the National’i^ol Marketings Corporation in the hale .of wools ; cbnsighed;to the iast-mentioned corporation by co-opeTa* tlve organlzatibhs of woolgrowers thrbughbut the United States; ■ (5) That-iri; its bohtract ..with the said National "^bl Market- ;y;-<;lng Corporation, the said Draper &■ Comply, Incorporated, agreed not ■ ’■ to conduct any businesB in domestic'grease.wools; �•: ■’ (6) That the said. DrEper & Company, Incorporated., has not . now and never hO-d a place of business or office in the State of '^yo;■ -niing;. ■■■■;/ '■■■ (7) - .._ . . That the said Draper & Company, Incorporated, prior to August, 1929, occa^dnhily bought.wools iii the State of ffyoming, which wools were always bought for immediate shipinent East and were actually shipped at once out of the State of Wyoming and not other­ wise handled, sold or dealt in until after such shipment had been made; (3) That since August, 1929, Draper & Company, Incorpora­ ted, has done no business of any nature on its own account in the State of Wyoming; (9) That at no time has Draper & Company, Incorporated, • conducted regularly any business in.; the State: of Wyoming, its only business activities there at any time being the purchase of wools at rare intervals as described, in the preceding paragraphs; i§31, when the' —■ P^fported. Bervice of Summons was attempted'to be made upon the said Draper &.;Company, incorporated, the said corporation had no agent in the State of Wyoming and had not since August, 1929, transacted any business of. any hature on its own account in the said State; (11) That Paul A, Draper, the person upon whom the pre­ tended service of summons was made in this case, was on tiie sixteenth day of April, 1931, a visitor in the State of Wyoming: on the invita­ tion of the Wyoming Wool Growers Association to attend their annual convention, and neither at that time nor any other acted as agent of : the defendant.in said State; no action was at any time taken by: the board of - directors of Draper & Company, ‘ Incorporated, in any way authorising': ' ■ the said Paul -At praper to act as the representative of the said cor­ poration in the State of Wyoming,^nor was action taken by the said board authorizing any ijidividuai to act as such representative in said -State. ■ ? �IN -JITO88 iVHERBOF, I, the said. George ff. Brown, being duly sworn, hereunto set my name this thirteenth day of June, 1931. CChhON fiKALTH Uj' ju^/^oionwHUSui-TTB Suffolk/ ss. ji^ne 13, 1931, On the thirteenth day of June, 1931, appeared the above named George '.V. Brown, personally known to me, and made oath that the statements contained in the above affidavit, by him subscribed, are true, �rroMXHa THE STATE COUMTT OF MATOOMA <wl! ' ) t sa ) «• \i.. . z, . X« T8I OX9TOXQT owirt,. is^4 ■'?•■"•<■=■.■■ 4 iA-: .■-- DISTRICT ■4.4 ROT B. Mim^ Plaintiff, - vg - DRAPER A COHPAET, a Corporation, XmO., Defendant. ) M07I0E TO QUASH Comes now the above named defendant, Draper A Company, Inc., a Corporation, and moves the Court for an order setting aside the summons, and quashing and setting aside the service of eummona and the sheriff's return of service made in the above entitled matter, and as grounds for said motion, respectfully shows to the court as follows: 1. That the defendant is a foreign corporation, duly organised and existing under and by virtue of the laws of the State of Kassachusetts, with its headquarters and principal place of hue* iness in the City of Boston in said state. S. That the defendant on the 16th day of April, A.D, 1931, the day when said purported service of eumnone was attempted to be made upon this defendant, was not transacting any buelneas of any kind in the State of Wyoming and did not have any agent, office, or place of business in eald state, nor had defendant transacted any business, or had any agent, office, or place of businese in the State of Wyoming, for many years prior to said April 16th, 1931. 3« That Paul Draper, the person upon whoa the pretended servioe of suauons was made, was not on eaid April 16, 1931, and never had been an agent of the defendant in the State of Wyoming, . •44 �fcBd on tatd dat« not ftgdftt «f tatd defendant In th# State of Wyoming, but was in the state merely ae a visitor, and not as an a^ent or off>o«r of tofendant oors«><atloa, er on - ii- bueiness connected with dependent pdr^fation. Attorney for Defendant? ■:»''''^ ’’■,<■5?. > y-- �1 V (this side 6 km 1931 I OrCARD IS FOR ADt^ESS ] ��SUMMONS THE STATE OF WYOMING COUNTY OF NATRONA ) I ss. j To the Sheriff of Natrona County, Greeting: V K commanded J , to . notify ..4, DHAPSl Ife C0HPAN7. XSC«« —a corporation. You are Vhereby *rT:T that. .ha-H. been sued in the District Court of the i^xth Judicial District of the State of Wyoming, sitting in the City of Casper, within and for the County of Natrona, in the State of Wyoming, for the trial of causes arising under the laws of said state by. .......... — ROT B. and that unless..... day of ....answer the petition of the plaintiff herein filed on or before the 19/^ said petition, with all the matters and allegations therein contained will be taken as true, and judgment rendered accordingly. And make due return of this writ according to law on the.„ .................. day of............ A. D. 19^^ Witness 3oXI^ MoDomM, thereof, at the City of Casper, this Clerk of the District Court, and the seal day of. — ..................... 19jZ5^* Cleric of Court. Deputy. 0 Z i I � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty vs. Draper and Draper and Company Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NoC-US/1.0/">http://rightsstatements.org/vocab/NoC-US/1.0/</a> Date Created Date of creation of the resource. 1931-1934 Description An account of the resource Plaintiff Case file of Roy B. Minty vs. Draper and Draper and Company. As part of the Roy B. Minty Papers, researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1920s and 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers, correspondence in regard to the Careyhust Ranch, as well as ledger books, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Text Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_MintyvsDraper_PlaintiffCaseFile Format The file format, physical medium, or dimensions of the resource PDF Extent The size or duration of the resource. 22.4 megabytes (133 pages) Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/2e4a7617f8ab36ff0acc749b531d9176.pdf 2e58c956c3659cfc7c6bc67477db8b96 PDF Text Text Triplicate ROY B. MINTY General Commission WOOL, SHEEP AND CATTLE Casper, Wyoming THIS CONTRACT, made this A. D. 19. .r.i.z , between day of of of party of the first, and party of the second part, * WITNESSETH: That for and in consideration of the sum of . ................. DOLLARS paid by said party of the second part to said party of the first part, in hand paid, said sum being a part of the purchase price, the re­ ceipt whereof is hereby acknowledged, said party of the first part hereby sells and agrees to deliver to said party of second part or their assigns. ewe - or all ewe or all„J' lambs from ‘*" ..... ewes, bred to ...,,*«^ampshire ....,ji-«eRamboui!let ........ Corriedale lambs from............................ ewes, bred to . ........................ or all ’'*«*«■ lambs from............................ ewes, bred to , . - ............. Half Blood April rams, to lamb in 19..... May ,ran-is, to lamb in 19..... ........ Hampshire . ............Rambouillet ........ Corriedale ....... ..... Half Blood ........ Hampshire . ........... Rambouillet ........ Corriedale , rams, to Iamb in March, 19.. V, ^1 ............. Half Blood or all old ewes, cut out of herds of first party, in fall of 19 and against which there is no Lien or Encumbrances, title being clear; and now ranging in , unshorn; between the day of .............. and the ............................day of . A. D, 19 at party of the second part’s option (definite date to be determined by second party upon thirty days’ written notice to first party or his agents) F.O.B. cars when railroad accepts shipment for final destination, weighing and inspection fees paid at on...; ;.*! .S: A."...';:? .t railway. Party of the first part to order cars for above sheep. Said sheep to be lotted in dry pens 12 hours oflf feed and water and to be weighed with dry fleeces; all sheep mentioned in this contract to be in good merchantable condition, to be free from scab and all other diseases; to pass both State and Government inspection. Lambs guaranteed to average at least ................. pounds at the price of ................................. per lambs under pounds rejected. All sick, crippled, excessively burry, wrinkled-bodied and buck lambs to be rejected. Old ewes guaranteed to be ONLY those RAISED by the party of the first part; to be FIRST CUT from herds in fall of 19.to be free from sick, shelly, crippled and ruptured sheep at the price of per subject to conditions above. Party of the first part further agrees not to otherwise dispose of any sheep, mentioned in above sale, and said sale covers all of this particular class of sheep owned by party of the first part unless otherwise stated. It is agreed a commission of....^Z... c per head will be paid Roy B. Minty, for total number delivered on this contract by party of . ..WA yjW.. .. part at time of this delivery. IN WITNESS WHEREOF, said parties have hereunto set their hands in triplicate the day and date aforesaid. In the presence �Triplicate ROY B. MINTY General Commission WOOL. SHEEP AND CATTLE Casper, Wyoming THIS CONTRACT, made this ;...........day of ............ ... A. D. 19..^:....., between of V.... ;.i.. Ab party of the first, and t...; ..'....v.i.. of ..<.;.i..—. ..... party of the second part, ? WITNESSETH; That for and in consideration of the sum of.?. ..r...... ...P. DOLLARS paid by said party of the second part to said party of the first part, in hand paid, said sum being a part of the purchase price, the re­ ceipt whereof is hereby acknowledged, said party of the first part hereby sells and agrees to deliver to said party of second part or their assigns, ■■’*** Corriedale ewe * V- ■ 'tenths ■froih:^\*".".r.~.-.”.T.rwes,*brer... ewe , ; ,, or all wpthpr Half Blood Corriedale « 1 lambs from It ;..................... ewes, bred to . Half Blood Rambouillet Half Blood--"”<'° May ...Tor aU old’ewes,' eut out "of herds of-‘first-party,’fti"fall‘<5f‘19' and against which there is no Lien or Encumbrances, title being clear; and now ranging in '. ................... , unshorn; between the;;;;;.....:. . day of.:.;.i.V..7.7.A....LT,.....7..^iTanJ the day of ..<.t ._ A. D. 19 .: at party of the second part’s option (definite date to be determined by second party upon thirty days’ written notice to first party or his agents) F.O.B. cars when railroad accepts shipment for final destination, weighing and inspection fees paid at.*. ........... ?............ ......................... on .................................. railway. Party of the first part to order cars for above sheep. Said sheep to be lotted in dry pens 12 hours off feed and water and to be weighed with dry fleeces; all sheep mentioned in this contract to be in good merchantable condition, to be free from scab and all other diseases; to pass both State and Government inspection. Lambs guaranteed to average at least ............................ pounds at the price of ...................... per All lambs under ................ pounds reiected,_ All sick, crippled, excessively burry, wrinkled-bodied and buck lambs to be rejected. Old'ewes guaranteed to Ee Ol^LY tiiose RAISED By' the party of the first'part;'to be FIRST CUT-from herds"in’^fstll'wf 'I97'...‘‘.'7?, 'to be'fl-'e’eTrorn sick,' shelly, Cfippled and ruptured Sheep at thd"price’ Of' 77'A7*.77....f)et subject to conditions above. Party of the first part further agrees not to otherwise dispose of any sheep, mentioned in above sale, and said sale covers all of this particular class of sheep owned by party of the first part unless otherwise stated. It is agreed a commission of . c per head will be paid Roy B. Minty, for total number delivered on this contract by party of of part at time of this delivery. IN WITNESS WHEREOF, said parties have hereunto set their hands in triplicate t - day and date_aforesaid- In the presence witness: First Part. �Triplicate ROY B. MINTY General Commission WOOL, SHEEP AND CATTLE Casper, Wyoounff , niaroe A. D. day of.. between of party of the first, an ..of party of the second part,' ■WITNESSETH: That for and in consideration of the sum DOLLARS paid by said party of the second part to said party of the first part, in hSnd paid, said sum being a part of the purchase price, the re­ ceipt whereof is hereby acknowledged, said party of the first part hereby sells and agrees to deliver to said party of second part or their assigns. ................... wptlipr 4 .• •* or all wcincr lambs from.............. wether ......................... or all wetner we wether or ' ”all • Hampshire ewes, ..bred................... to ............ Rambouillet . 4 m • March, 1 rams, to lamb 19.... ........... Corriedale .............. Half Blood <lambs « from <• > ...... ............ ......... ewes, bred to........ Hampshire-......... Rambouilletrams, to lamb in 19..... -,4 „ ........ Corriedale .......... Half Blood , v r • i, . t j , ........'...*l«wyaBtre ........ Rambouillet May lambs from....... .....................ewes, bred to_____ „ „ .rams, to lamb'-in 19.tW .........OecrtCQUe .......... Half Blood or all old ewes, cut out of herds of first pa and against which there is no Liem^r Encumbrances, title being.clear; and now ranging , unshorn; between the .^J^i'*^**". day of .. *.......... and the ............ day of... A. D. 19 .5^ at party of the second part’s option (definite date to be determined by second party upon thirty days’ written notice to first party or his ments) F,O.B, cars when railroad accepts shipme^ for final destination-weighing and inspection fees paid at . ^.'1'^.^........,.. ....railway.- Party of the first part to order cars for above sheep. Said sheep to Ifc lotted in dry pens 12 hours off f^d and water and to be weighed with dry fleeces; all sheep mentioned in this contract to be in good merchantable condition, to be free from scab and all other diseases; to pass both State and Government inspection. 7 J Lambs guaj^teed to average at least '.41?. pounds at the price of ...................per AH Iambs under pounds rejected. All sick, crippled, excessively burry, wrinkled-bodied and buck lambs to be rejected. Old ewes guaranteed to be ONLY those R.A.ISED by the party of the first part; to be FIRST CUT from herds in fall of 19 . 1^., to be free from sick, shelly, crippled and ruptured sheep at the price of 1.......... per subject to conditions above. Party of the first part further agrees not to otherwise dispose of any sheep, mentioned in above sale, and said sale covers all of this particular class of sheep owneff by party of the first part unless otherwise stated. is agreed a commission ofJFs?. c per head will be paid Roy B. Minty, for total number delivered on this contract by party of part at time of this delivery. IN WITNESS WHEREOF, said parties have hereunto set their hands in triplicate the day and date aforesaid. In the presence �Triplicate ROY B. MINTY General Commission WOOL, SHEEP AND CATTLE Casper, Wyoming .f THIS CONTRACT, made this •■'■'Z ......................... day of..A.A.Z-: .................................. ...... -■■/■■■...... ;•••• ............... ......................................... D. 19::;...?..., between "■■■/............................^...•K-.a.................................................... party of the first, and'A..\f....f:..t /s...‘...t......st party of the second part,..........................................>............................... j WITNESSETH: That for and in consideration of the sum of DOLLARS paid by said party of the second part to said party of the first part, in hand paid, said sum being a part of the purchase price, the re­ ceipt whereof is hereby acknowledged, said party of the first part hereby sells and agrees to deliver to said party of second part or their assigns. ....... or all wether ewe lambs from.................. .......... ewes, bred to ....... or all wether ewe lambs from.............. ;.... ......... ewes, bred to U.... or all wether ewe lambs from../*..::..*:... 1:.-. ..ewes, bred to ..... Hampshire .... ...... Rambouillet ..... Corriedale ..... ........ Half Blood ..... Hampshire .... ...... Rambouillet ..... Corriedale ..... ........ Half Blood ..... Hampshire ............ Rambouillet ..... Corriedalc rams, to Iamb in March, 19.... rams, to lamb in .rams, to lamb in ..... ........ Half Blood April May 19.... 19.... .......... or all old ewes, cut out of herds of first party, in fall of 19...»: and against which there is no Lien or Encumbrances, title being clear; and now ranging in : , unshorn; between the day of ....... and the...a..,^. ...... day of _. ...................... A. D. 19 at party of the second parTs opHon (definite date to be determined by second party upon thirty days’ written notice to first party or his agents) F.O.B. cars when railroad accepts shipment for final destination, weighing and inspection fees paid at ........................ .?. ,...: on..... railway. Party of the first part to order cars for above sheep. Said sheep to be lotted in dry pens 12 hours off feed and water and to be weighed with dry fleeces; all sheep mentioned in this contract to be in good merchantable condition, to be free from scab and all other diseases; to pass both State and Government inspection. y / Lambs guaranteed to average at least .......................... pounds at the price of '. .1........................ per All lambs under pounds rejected. All sick, crippled, excessively burry, wrinkled-bodied and buck lambs to be rejected. Old ewes guaranteed to be ONLY those RAISED by the party of the first part; to be FIRST CUT from herds in fall of 19....... .., to be free from sick, shelly, crippled and ruptured sheep at the price of ......... per subject to conditions above. Party of the first part further agrees not to otherwise dispose of any sheep, mentioned in above sale, and said sale covers all of this particular class of sheep owned by party of the first part unless otherwise stated. It is agreed a commission ofZil.;... c per head will be paid Roy B. Minty, for total number delivered on this contract by party of part at time of this delivery. IN WITNESS WHEREOF, said parties have hereunto set their hands in triplicate the day and date aforesaid. In the presence of witness: Party of the First Part. .Party of the Second Part. �Triplicate ROY B. MINTY General Commission WOOL. SHEEP AND CATTLE Casper» Wyoming THIS CONTRACT, made this... ........................ ............. ................. party of the first, and.....■r..:*:.A-..*;. party of the second part, WITNESSETH: That for and in consideration of the sum of DOLLARS paid by said party of the second part to said party of the first part, in hand paid, said sum being a part of the purchase price, the re­ ceipt whereof is hereby acknowledged, said party of the first part hereby sells and agrees to deliver to said party of second part or their assigns. k............... ....... or all wether ewe lambs from. ...k^. or all wether ewe lambs from. ...ewes, bred to wether ewe lambs from: ...ewes, bred to .... .A-:....or all ...ewes, bred to ..... Hampshire ..... ...... Rambouillet rams, to lamb in March, 19. ..... Corriedale ..... ........ Half Blood ..... Hampshire ..... ...... Rambouillet ..... Corriedale ..... ........ Half Blood rams, to lamb in ..... Hampshire ..... ...... RambwsfflWr ..... CwpwWe ..... ........ Ha« «lood"^”®’ lamb in -April May 19 19 ........ or all old ewes, cut out of herds of first party, in fall of 19 .1 ■ ** and against which there is no Lien or Encumbrances, title being clear; and now ranging in... , unshorn; ■ > z' , J between the Z'.'...''......... day of ..........................and the....-: r.......... day of.......... ......................................... A. D. 19 at party of the second part’s option (definite date to be determined by second party upon thirty days’ written notice to first party or agents) F.O.B. cars when railroad accepts shipment for final destination, weighing and inspection fees paid at '.................... on,-Z.f’.^.... -t railway. Party of the first part to order cars for.above sheep. Said sheep to be lotted in dry pens 12'hours off feed and water and to be weighed with dry fleeces; all sheep mentioned in this contract to be in good merchantable condition, to be free from- scab and all other diseases; to pass both State and Government inspection. . Lambs guaranteed to average at least .'f.......................... pounds at the price of per All lambs under ...........pounds rejected. All sick, crippled, excessively burry, wrinkled-bodied and buck lambs to be rejected. Old ewes guaranteed to be ONLY those RAISED by the party of the first part; to be FIRST CUT from herds in fall of 19 ■.., to be free from sick, shelly, crippled and ruptured sheep at the price of ....... per subject to conditions above. Party of the first part further agrees not to otherwise dispose of any sheep, mentioned in above sale, and said sale covers all of this particular class of sheep owned by party of the first part unless otherwise stated. It is agreed a commission c per head will be paid Roy B. Minty, for total number delivered on this contract by party of Z.J part at time of this delivery. IN WITNESS WHEREOF, said parties have hereunto set their hands in triplicate the^y and date aforesaid. In the presence witness: I / ..................................................................................... .. ,■ , . / -^*^^rty of the First Part. Party of the Second Part. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Commission Slips Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1938 Description An account of the resource This digital record consists of 5 commission slips from 1938 that are a part of the Roy B. Minty Papers. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledger books, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_CommissionSlips_1938 Format The file format, physical medium, or dimensions of the resource PDF Extent The size or duration of the resource. 1.42 megabytes (5 pages) Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/ef54108e076ddd5dc5d809fae2a581fb.pdf b77b2266b8d2c23dd5433e822a3dc462 PDF Text Text BOSTON WOOL TRADE ASSOCIATION H. Clyde Moore, president Percy E. Sheldon, vice-president C. Willard Bigelow, sec.-treas. 263 SUMMER STREET November 18, 1938 Circular #361 To All Members Gentlemen: TRADE agreement WITH THE UNITED KINGDOM ' - — Signed November 17, 1938 Raw wool is not included in the Agreement, The duties on Wool Wastes, Tops, Yarns, and Manufactured goods are reduced by varying amounts (see schedule attached), The duties on most wool manufactures are compound; the specific portion is intended to compensate for the duties on raw wool, and the ad valorem portion to pro­ vide protection for domestic manufacturers. The specific duties on wool manufactures are in general not changed, but there is a provision that if hereafter the duties on raw wool are lowered, the specific rates will be correspondingly reduced. The most important concession is on woven fabrics weighing more than four ounces per square yard (total imports in 1937, $8,750,000; from the United Kingdom, $7,300,000). Under the most-favored-nation treatment, con­ cessions by the tmrted states apply to all nations except Germany. The Agreement will go into effect on January 1, 1939, for an initial period of three years, and may continue in force Indefinitely thereafter, subject to termination by either Government on six months’ notice. Yours very truly, H. CLYDE MOORE President �TEE TRADE ACffiEEMEUT WITH HIE UNITED KTOCTOM Signed November 17, 1938 Concessions on Imports Into The United States Par., act of 1930 Rate of duty Description of Ooramodity Before Agreement 1105 (a)&(b) 1106 .. 1107 .. IlOa 1108 .. V/ool and hair waste: Top, slabbing, roving, and ring waste ..................................... 37 5^ lb.................... Garnetted waste ............................. 26sJf lb.................... Wool noils: Carbonized ...................................... 30$? lb................... Not carbonized ................ 23gf lb.................... Thread or yarn waste .................. 259? lb.................... Card or burr-waste; Carbonized ..................................... 239? lb.................... Not carbonized .......................... I69? lb.................. Wool wastes, n.s.p.f. 249? lb.................. 24^ lb.................. Shoddy and wool extract ......... Mungo ................................. ............... 10{^ lb.................. Wool rags ............. .. I89? lb.................. Flocks .............................................. Q(f lb.................. Wool and hair advanced not further than roving, HIGLUDING TOPS. 379? lb. 4. 20^... Yarn, wholly or in chief value of wool, other than Angora rabbit hair; Valued at not more than 60(zf per lb......... ................... ............... 4O9? lb. -4- 35%... Valued at more than GOjf but not more than $1 per lb.... 4O9? lb. 4- 35%... Valued at more than $1 but not more than $1.50per lb... 409? lb. HK45%... Valued at more than $1.50 per lb................................. 40!/ lb. -4-5O?5. .. Woven fabrics, weighingHot— more than 4 oz, per sq, yd., wholly or in chief value of wool; Without warp of cotton or other vegetable fiber; Valued at not more than $1.25 lb.................................... 5O9? lb. 4-50%... Valued at more than $1.25 but not more than $2 per lb. 50{/ lb. + 55%... Valued at more than $2 per lb. 50^ lb. -f- 60% V/oven fabrics, weighing not more than 4 oz. per sq. yd., wholly or in chief value of wool; With warp of cotton or other vegetable fiber— Valued at not more than $1 per lb, ................................. .. 4O9? lb. +-50% Valued at more than $1 but not more than $1.50 per lb. 40$ lb. -+-55% Valued at more than $1.50 per lb 40$ lb. 4-60% Under Agreement Reduction of duty Percent 34(/ lb . I80? lb............. . Q 31 21(/ lb........ 16(/ lb................ 15rf lb.................. 30 40 18(7 14^ 14$ 14$ 9 9j^ 5$ lb........... .... lb................ lb................ lb................ lb ......... lb................ lb............ 37$ lb. +- 12i%. 12.5 42 42 10 50 12 / 30</ lb. -1 30^ 36$ lb. 4- 30% 40$ lb. -4-30% 19 40(/ lb. 4- 30^ 50$ lb. -+- 37^ 13 50$ lb. 4- 37^ 50$ lb. 4- 37|% 20 30 40$ lb. 4. 37^ 13 40$ lb. -j- 37^ 40$ lb. -+■ 37|% 20 27 �The Trade Agreement vdth the United Kingdom Par., act of 1930 Page 2 Rate of duty Description of Ccxmodity Before Agreement 1109 1109 (b) 1110 1110 1111 1112 1113 1114 (b) 1114 (b) Woven fabrics weighing more : than 4 oz. per sq, yd.,wholly: or in chief value of wool : (except woven green billiard : cloths, vjholly of wool,vreigh-: ing more than 11 but not more: than 15 02. per sq. yd.): : Valued at not more than 8O9?.: per lb......................... : Valued at more than 8O9? lb. : but not more than $1.25 per: lb : Valued at more than $1.25 : but no-^ more than $2pcr-lh^ ■^“Valued at more than $2 per lb Woven wool felts for machines: Valued at not more than $1.25 per lb ,......... Valued at more than $1.25 but not more than $2 per lb Valued at more than $2per lb. Plushes, velvets, and other pile fabrics of wool and other hair: Pile wholly cut or wholly uncut ................................... Pile partly cut . Manufactures of plushes, velvets, and other pile febiics of wool and other hair: Pile vdiolly cut or wholly uncut ........... Pile partly cut .......... Wool blankets, etc., not over 3 yds, in length; Valued at not more than $1 per lb ........... Valued at more than $1 but not more than$L.5O per lb. Valued at more than $1.50 -•..jaST lb. Felts of wool, not woven:. Valued at not more than $1.50 per lb. ............... ............... Valued at more than $1.50 per lb ......... Fabrics v/ith fast edges not over 12 inches in width and articles made therefrom (in­ cluding tubing, garters, etc.), wholly or in chief value of I wool. Wool hosiery, not embroidered: Valued at more than ;(pl.75 and not more than $3 per doz.prs. Valued at more tiian $3 per doz. prs .................... Gloves and mittens or wool, knit or crocheted (not em­ broidered) : Valued at more than $3.50 per doz. prs . Reduction of duty Under Agreement Percent 509? lb. + 50^0 409? 509? lb. 4 50% 505^ lb.4- 40%.. 50^ lb. 55%.., 60%.., 45%.. 50^ lb .4 40%.. 50 9? lb. -H 35%. . 17 32 509? lb. 4 25%^. 509? . Bound 50 9? lb. 5O9? lb. 5O9? lb. 45O9? Ib. 4 30%. . Bound Bound 449? 449? □UyOe • • 55%... 449? lb. 4449? 3O9? lb. 449? lb.4- 40%. . 449? Ib. 4 40%. . 12 22 44:^ Ib. lb. 4 14 20 SI;; 36%. 30 9? lb. 4 36% "Six} lb. 4- 37i% lb. 4- 36% 4Q9? lb. 4 40%. Bound 2 1 309? lb. 4 35% 309? lb. 4- 30%.. 7.5 409? lb. 4 40% 409? lb. 4- 35%. . 9.5 509? lb.+ 509? lb. 4 40%.. 5O9? lb. 4 505^3 5O9? lb. 4- 35%.. 5O9? lb. 4- 50% 5O9? lb.4 25%.. 509? Ib.-k 50%. 509? lb. -h 40%.. 15 �The Trade Agreement with the United Kingdom Par., act of 1930 Page 3 Rate of duty Description of Commodity Before Agreement 1114 1114 (d) 1114 1115 1115 (b) 1116 (b) 1116 (b) 1117 1119 ... 1120 Knit underwear of wool; Valued at not more than (pl,75 per lb Valued at more than ();i.75 per lb Infants’ vrool knit outerwear (other than headwear), n.s.p.f.*, valued over (p2 lb.: Jersey .............. Other than jersey . Wool knit outervrear (other ihan headv/ear and infants’ outer­ wear), n.s.p.f.’!'; Valued at more than ^2,,.hut —not more than ^5 pur lb. Valued at more than .jibperlb. Viool wearing apparel (except hats and hat bodies) not knit or crocheted: Valued at not more than ^4 per lb . Valued at more than $4 per lb . Bodies, hoods, forms and ai^s for hats, bonnets, caps, berets, or similar articles of wool felt, if blocked, trimmed, or finished, valued at more than $12 per doz. Under Agreement 40;^ lb.-4- 30%,.. 409f lb. -t-30%.. Bound 5O9f lb. -)-30%|f.. 5O9f lb. -+-30%.. Bound 5O9f lb. 4 25%... 5O9f lb. _|_ 75%... 5O9f lb. -1-25%., 509^ lb. -j-50%.. Bound 29 50^ lb?4- 50%... 50gf lb. 50%... 5O9f lb.-t-40%.. 5O9( lb. -1-30%.. 339; Ib.-t- 45%... 5O9( lb. -f—50%,.. 339? lb.-4-30^J.. 50/ lb. 4-30%.. 12«9f ea. 4-40^^ lb. 6d ea.+ 40/ lb. d- ^0 H55% Chenille axminister ca3?pets and rugs . Rugs of oriental vjeave made on a povrer-driven loom............... Machine-made wool carpets,rugs matSj etc.: Axminster, n.s.p.f.*; Vftlton: velvet and tapestry; Brussels; and carpetsand rugs of like character or description: Valued at more than 409? per sq.__ft.-_ __ __ Floor coverings of mohair: Valued at not more than 40^ per sq. ft Valued at more than 409f per sq. ft ........................ Tapestries and upholstery goods (except pile fabrics) of vrool and other hair. Reduction of duty 40% #........... .. .................... 25 34 25.5 (est.) Bound 40%.................... 33 60%....................... __ 40% 33 30%...................... •5^0.................... 60%.................... .. .......... Same rates as on Same rates as on wool fabrics pro-txrool fabrics pro:Tided for in Tided for in * pars. 1108 and :pars. 1108 and :1109 (a) of this 1109 (a). ; schedule. Bound 33 30 (est.) Manufactures of wool,n.s.p.f.* Cloth samples measuring not 50 : 25% 50% more than 104 sq. inches. Explanation of Reference Marks * (n.s.p.f.)—Not specially provided for. Reduced rate of duty proclaimed under a previous trade agreement wi-tii another ccuntry Bound—Assure that the existing treatment will not be made less favorable during the life of the agreement. �LUCAS-HENKELS COMPANY MAI EAR 294 SUMMER STREET BOSTON CHPISTMA Mr. Robert Grieve Henning Hotel, Casper, Vi/yoKilng � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Trade Agreement with the United Kingdom Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1938-11-17 Type The nature or genre of the resource Text Creator An entity primarily responsible for making the resource Boston Wool Trade Association Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_TradeAgreement Format The file format, physical medium, or dimensions of the resource PDF Extent The size or duration of the resource. 1.42 megabytes (5 pages) Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/05ce244f499ffc69a6de628e3dfca8b9.pdf 604fee369649ea110d5d41913bed4c2a PDF Text Text Form. FSx’x-X, RR 58 7/5/38 Denver, Colorado CNITSD STATES DEPARTLISNT OF ACRICULTURE F/JJM SECURITY JiDWHHSTR/tTION Denver, Colorado TO ATI. BUYERS .'iND OTHERS CONCEEIvED IK THE lEARKETTNG OF CROPS END LIVESTOCK IN THS STANCES OF COLOR.U3O, MOOTIiNA .^ND WYOMING. The attached lists give the names of persons viio have been granted Rural Rehabilitation loans out of funds appropriated by the Congress of the United States. These loans are secured by mortgages on crops, livestock and other chattel property. This list is furnished for your convenience. All of the above instruments are of record in the proper counties and afford legal notice of the Government’s prior claim to the proceeds from sale of crops or livestock described therein. Purchasers of mortgaged crops or livestock take such property sub­ ject to the mortgage, and are required to protect the interests of the lienholders. Before making payment for the purchase of any crops or livestock, it is requested that you first consult the attached list. If you find that the person vdiose crops or livestock you are about to buy or otherwise handle is listed as a debtor of the Government you should include the F.IHM SECURITY .'kDlHNISTRATION as one of the payees on the check or draft written in payment for the mortgaged chattels purchased. This check or draft should be delivered to the Authorized Rural Rehabilitation Supervisor if he is present at the time the sale is made or mailed to; ~ ' - Jack L.-Ankney____________________ County Supervisor Farm Security Administration U. S. Department of ^agriculture Caaper, Wymning , » ' If the remittance is mailed direct to the County Rural Rehabilitation Supervisor, it should be accompanied by a statement shoiiVing the borrower’s loan number, name, and address, exactly as they appear on the attached list, together with a statement showing the property purchased. Your attention is directed to the fact that debts due the United States are payable in lawful money of the United States at par without deduction, and vdiere a debtor or any person acting in a debtor’s behalf elects to remit by check, it is necessary that the check be paid at par. It is our desire to facilitate the orderly marketing of crops and livestock. It is to your advantage that you check all transactions against the attached list, and against existing chattel records. UNITED STATES DEP.VRTIffiHT OF AGRICULTURE FARM SECURITY ADMINISTRATION ----- B C. H. Willson Regional Director �UNITED STATES ZEPAHTISCT OF AGRICULTURE EARN SECURITY ADMINISTR^iTION BORROVSRS Julj' - 1939 Natrona County Address No. Nane ... ' 200392 208755 206755 200393 2014-01 206319 201074 206301 204126 206541 200397 206849 201466 200399 200990 204023 200890 200-402 2G5682 200891 207216 206555 206145 202652 204-443 207204 200407 205398 201473 205700 202655 20079a. 200411 205615 203701 203845 206331 206331 200413 206303 200414 200415 2J6330 205«11 200885 200416 200889 201429 206520 006877 203393 £0651 J 20'0151 201-081— ----203536 20>-,70C 200418 201431 204484 206301 200420 200421 201567 202654 204280 1315 S. McKinley, Casper Akers, Joseph Alcova Route, Casper Alexander, Isaac S. Alcova Ro-.te, Casper Alexander, Freeland T. Hiland, Wyoming Baker, Sam 11. Box 1074, Casper Barnes, Rae D. Box 1552, Casper Beaven, Joseph A, Gen, Del. Casper Benson, Clarence Alcova Ro’.'te, Casper Bilek, Albert Ki land, Wyo. Bird, Bryan • Alcova Route, Casper Brejcha, Charles 153 N. Durbin, Casper Burd, Ross A. Box 1130, Casper Campbell, Thomas Natrona, Wyo. Casebolt, Robert Natrona, Wyo. Caves, Jaiues A. Box 2224, Casper, ’Wyo. Cheney, Thomas P. Box 1725, Casper, 'Wyo. Collins, Cecil W, Natrona, Wyo. Combs, Thomas V/. Raderviile Route, Ce.sper Davis, Alvin E. Freeland, Wyo, Dickinson, Bertram N. Evansville, Wyo, Diehl, Charles T. Box 96, Mills, Wyo. Dockham, Roscoe C. Kaycee Rt. Midwest, ’,7yo. Engels, Fred Hi land, Wyo. Garrison, William F. Box 123, Casper, 'Wyo. Gersic, Martin Lysite, Wyo. Gourley, Harry Box 1625, Casper Hartman, George Natrona, ’W-o. Hastings, Vlarren Salt Creek Rt. Casper Hinerraan, -Angus W, Evansvilie, VZyo. Jensen, Hans Box 24, Mills, Wyo. Johnson, Edv/ard C. Natrona, vyo. Jol'jison, Finch L. ... - .-Box. 14,. Jhianavi.! la^Jyo. Kelsey, Earl ___ Alcova Route, Casper Kerns, William J. 831 S, ’Washington, Casper ■IcFarland, Harold A. Alcova Route, Casper McKinnon, Byron L. Box 2223, C’sper, Mapes, Hurshel 3, Hi la nd, 'Uvo. Moigh, Love 5/ K. Niland, ’.'yo. Meigh, Robert Box 1713, Casper, Wo. Mills, Jack BeX 1570, Casper, W-o. Mosteller, Charles VZ. Box :>l-4, Casper, W-yo. Mci'.e, Alien F. Box 614, Casper, Wyo. Mote, Edward F. Midvzest, Wyoming Murphy, James E. Niland, k'yo. Neff, Laurence R. Evans v i 11 e, ' .'yo. P;;tchen, Melvin rvansvi lie, ■'■yo. Pierce, Lewis J. Gen. Dei. Casper, Wyo. Pinney, Melvin .jminto, Wyo. Potter, William H. Natrona, Wyo. Proctor, W. A. & W. H. Raderlilie Rt. Casper Rader, Mattie B. -.’JLcova Route, Casper Rossin, Robert Na+rona, Wyo. Savage, Charles Alcovc. Route. Casper Schloss, John D. Streety^ Leweir B.-------------- -------- Box 254&, Casper, 'Wyo. Kills, '^Tyo. Struck, Edward D, Box .■1130. Casper, Wyo. Tisdale,'John Toothraan, Oscar E. Ns trona, Wyo. 854 3,. J.ackson, Casper Tope, Joseph E. .ilcova Route, Casper Viers, John S. Alcova ■Route, Gasper Vodehnal, James Salt Creek Rt.. Casper ilelty, John P. Box 737, Casper nest, Robert A. Box 1327, Casper ..entz, lirs. J. E. Hi land, 7/yo. VZight, Guy Wintermote, Lavzrence Raderville Rt. Casper � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Natrona County Rural Rehabilitation Loan list Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1938-07-05 Description An account of the resource July 5th, 1938 United States Department of Agriculture Rural Rehabilitation Loan list for borrowers in Natrona County from the Roy B. Minty Papers. Minty's papers consist of correspondence, data on Wyoming sheep ranchers, correspondence in regard to the Careyhust Ranch, as well as ledger books, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Text Language A language of the resource ENG Is Part Of A related resource in which the described resource is physically or logically included. Roy B. Minty Papers Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RuralRehabilitationLoanList Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/ab55169226542cc4aff148910364d36a.pdf bb784e737a96e65355265da541968e6e PDF Text Text Zb pasHMUBt of fow BottArad TblW Pilars (*4^«00) aad other raloBhla aonelderaKoQ«» the receipt of ahi eh 1« hereby eei^oo^Iedged md Ci^t^eseed, X hereby eeelgB all Mile .end, iBtereat iB .ead to-eemleeloaa cm—' ■-•Wje s*?X® of hedhe were g3eo4fs.efaiy fewrlhed In a eoatreet, <»» ot whieh la etteehed hereto* glren la-tlay* 1933 by and between the CoohlB^en @hea|^ GOa|j«^ of Pendleton, Oro@oa» party of the ft ret part* Boy B, Sloore, Waaatoa, l^lJig* party of the seooad part, B* ai»i^ of Gaaper* Wyoe^lag, party of the third part. the oomlosloas that er® being aeslgned in this Aasiga« west corer the oontraets for ^e pwohase of hus^s to the following ladlwldsals and she amber of hmhe as sat opposite ^elr aAee: Z»» !.« auM^ iSamyaay boate L«wd & Llveetock CO9 HlXow Greah ^e«^ 0o» Z« i^heap' OEN^peny. 100 he«^ » so 21S wttaossi Oatoa ®t CaaiPWg I^Qiaiae l&l,® Ist <ay 9t Atigwat, 1939, **4 ■ " ■ i 4 ! ^fe u< • - WSi- >* -/a-f-" ‘F^' � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Receipt of Assignment Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1939-08 Description An account of the resource Receipt of assignment in and to commission on the sale of bucks found in the Roy B. Minty Papers, which consist of correspondence, data on Wyoming sheep ranchers, correspondence in regard to the Careyhust Ranch, as well as ledger books, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Text Language A language of the resource ENG Is Part Of A related resource in which the described resource is physically or logically included. Roy B. Minty Papers Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_ReceiptofAssignment_1939 Format The file format, physical medium, or dimensions of the resource PDF Extent The size or duration of the resource. 1 page Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/21c0a911cc6de9dba8955923c58f99f2.pdf 09556984e5de9624ba036a041589329b PDF Text Text BURT GRIGGS Attorney - at - Law Buffalo, Wyo. THIS MESMOHMDOT OF O AGaEH.'SHT', made and entered into this November 6", 1925‘i by and between Young Brothers and laing and Balden^ of Johnson County, Wyoming, first parties'*, and Roy B. Minty, of Casper, Wyoming, second party, WITNESSETH: -y That for and in consideration of one dollar and other good and valuable considerations paid to the first parties by the second party’, the receipt whereof is hereby confessed and acknowledged, the said first parties do hereby give and grant unto the second party an exclusive option to purchase the following described lands and premises, situate, lying and being in Johnson and Washakie Counties’, Wyoming^ to-wit; The southeast q.uarter of the northeast q.uarter (SEi- NEi-)‘i the northeast quarter of the southeast quarter (NBi SEi-K the southwest quarter of the southeast quarter southeast quarter of the southvzest quarter (SeJ SwJ) Of Section Thirty-one (31) in Township Forty-six (46) North of Range Eighty-five (85) West of the Sixth Principal Meridian. g Lots Four (4), Five (5) and Seven (7)", the southeast quarter of the northvzest quarter (SEl NVifJ-), the southwest quarter of the northeast quarter (SWj HE^), the southwest quarter of the southeast quarter (SW-J- SEi) and the southeast quarter of the southwest quarter (SeJ SVZ-t) of Section Six (6): the southvzest quarter of the northeast quarter (SW-i NEt) » the north half of the southeast quarter (N-J- SE-i)", Lot Four (4) and the southeast quarter of the southwest quarter (SEi- SW-^) of Section Seven (7); the south half of the northeast quarter (S-i NE-i)", J,ot Three (3) and the northeast quarter of the southwest quarter ■fNEi SWi) of Section Ei^teen (18); Lot Tvzo (2) of Section Nineteen (19); Lots One (1) and Three (3) of Section Thirty (30) in Township Forty-five (45) North of Range Eighty-five (85) West of the Sixth ^'rincipal Meridian. The lands in the above two townships are in Johnson County^ Wyoming. Kie south half of the southeast quarter (S^- SE^-) of Section Thirty-five (35) in Tovznship Forty-six (46) North of Range Eighty-six (86) West of the Sixth Principal Meridian. Lots One (I)’, Two (2)^ Three (3) and Four (4) and the southeast quarter of the southeast quarter (SEi SEi^) of Section One (1); Lots One (1) and Two (2) and the southeast quarter of the northeast quarter (SE-J NE^-) of Section Two (2); The southeast quarter of the southwest quarter (SEi- SW^-) of Section Ten (10): the southvzest quarter of the southwest quarter (SWi SWi) ^^ the northwest quarter of the southeast quarter (NWi SEi) of Section Eleven; the southwest quarter of the northwest quarter (SWi NWi) of Section Twelve (12); the 1 * I * �north, half of the south half (H'^ S-g) and. the southvzest quarter of the northwest quarter (SWf KWi) of Section Thirteen (15), the vzest ^If of the southwest q.uarter SWj-) of Section Pop7teen (14) and. the east half of the southeast q.xiarter (Eg- SEf-) of Section Fifteen (15); the southeast quarter of the northeast quarter (SEi- HEi)', and. the northwest q^uarter of the southwest quarter (Wf SWf) of Section Twenty-two (22); the northwest q.uarter of the southvzest <iuarter (Wi- SWf) of Section pizenty-t^ee (23); the southeast quarter of the northeast q.uarter (SEa lTE4-)‘i the north half of the southeast quarter (Hg- SE^j and. the southvzest quarter of the southeast qxiarter (SVif^- SE-^) of Section Twenty-four (24); the north half of the northeast quarter (E-g- HSt) and. the northvzest quarter of the southeast quarter (Wf SEf) of Section Twenty-five (25); the east half of the northvzest quarter (Bi- W-J) and. the southwest quarter of the northvzest quarter (SW|- EWi) of Section Twenty-seven (27)* the southeast quarter of the northeast quarter (SE-J EEi) * and the north hahf of the southeast quarter (Ei SeJ) of Section Thirty-three (33); the northwest quarter of the northeast quarter (EW^ EE4-), the northeast quarter of the northwest gnaytay (EEf E?/i) and. the southwest quarter of the northwest quarter (SW-g- EWt) of Section Thirty-four (34) and. the southeast quarter of the southeast quarter (SEi SEf) of Section Thirty-four (34) in Township Forty-five (46) North of Range Eighty-six (86) West of the Sixth Frincipal Merid.ian. The two last townships above mentioned are in Washakie Countv. Wyoming. ’ Also the certificates of purchase of state lands as follows; The northeast quarter of the northeast quarter (EEi EEir) of Section Twenty-three (23); the southeast quarter of the northeast quarter (SEf EEf) of Section Twenty-two (22);the northwest quarter of the northeast quarter (EWi- EE-^) and the southwest quarter of the northwest quarter (SWi- EwJ) of Section (26); the southeast quarter of the northwest quarter ISE4 EWt) and the northeast quarter of the southwest quarter (EEt SWf) of Section Twenty-five (25); and the northeast quarter of the northvzest quarter (NE-i- EW^) of Section Thirty-five in Tovznship Forty-five (46) North of Range Eighty-six (86) West of the Sixth -principal i-eridian. Also the lease of School Section Thirty-six (36) in Township Forty-six (46) North of Range Eighty-six (86() West of the Sixth Principal I^eridian. Also the southwest quarter of the northvzest cuarter (SWi W) of Section Twenty-nine (29) in Township Forty-five (45) North of Range Elghty-slx (86) West of the Sixth Principal Meridian. The said second party is given an option, for a period of one hundred t’zzenty days from and after November 10, 1925, to purchase the said lands and premises for the prices and upon the terms and conditions following, to-vzit; RIX. •a • / The consideration of nine dollars per aere/excepting as to 2 �the Xec* 29 Tp. 45 H. R. 86 W. aforesaid., for which the consideration shall be $4.50 per acre.^ The sum^of one half of the entire purchase price shall be paid, down in cash at the time > the option is exercised^ and the balance shall be payable in three years with interest at the rate of seven per cent per annum. The purchaser shall pay the taxes for 1926 and subsequent j > . years. As to the lands held under certificate of purchase, the first parties agree to assign said certificates to the second party or his assigns upon the payment of the sums of money usdiich have been paid by said first parties to the State of Wyoming up to the date of purchase by the second party, and the purchaser shall assume and make all subsequent payments to the state. The school section will be assigned without further con­ sideration. Thia agreement shall be binding upon and inure to the benefit of the heirs and nominees of the second party. IH WITNESS 7/HEREOP this agreement has been executed in duplicate the day and year first above v.-ritten. ? � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Roy B. Minty Papers Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Date Created Date of creation of the resource. 1930-1939 Description An account of the resource Roy B. Minty was a livestock broker out of Casper, WY. His office was located in the lobby of the Henning Hotel. Researchers will find letters and telegrams exchanged between Minty and Draper and Draper Incorporated Wool out of Boston, Massachusetts among other items of potential interest to the sheep and wool industry in Wyoming during the 1930s. Minty's papers consist of correspondence, data on Wyoming sheep ranchers from 1934, correspondence in regard to the Careyhust Ranch from 1937-1939, information on a Wind River Day School lamb sale, as well as ledgerbooks, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Collection Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Language A language of the resource ENG Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2023.03_RoyBMintyPapers Extent The size or duration of the resource. 37.5 megabytes (3 folders, 43 files) Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Memorandum of an Agreement Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/NKC/1.0/">http://rightsstatements.org/vocab/NKC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of these records. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1925-11-06 Description An account of the resource Memorandum of an Agreement between Young Brothers and Laing and Balden, of Johnson County, Wyoming, first parties, and Roy B. Minty of Casper, Wyoming, second party as found in the Roy B. Minty Papers. Minty's papers consist of correspondence, data on Wyoming sheep ranchers, correspondence in regard to the Careyhust Ranch, as well as ledger books, settlement slips, bills of sale, contracts, agreements, and more. These records date from the late 1920s to the late 1930s. Type The nature or genre of the resource Text Language A language of the resource ENG Is Part Of A related resource in which the described resource is physically or logically included. Roy B. Minty Papers Format The file format, physical medium, or dimensions of the resource NCA 01.ii.2023.03_MemorandumofanAgreement Extent The size or duration of the resource. 1.56 megabytes (3 pages) Source A related resource from which the described resource is derived Roy B. Minty Papers, NCA 01.ii.2023.03 WyCaC US. Casper College Archives and Special Collections. https://caspercollege.cvlcollections.org/files/original/e5479d3b0a4d76528b23d0a450ef73f1.jpg 55049f779b9d0dfcee8f36690fc9339d Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alan K. Simpson Photographs Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/InC/1.0/">http://rightsstatements.org/vocab/InC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of photographs. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Subject The topic of the resource Politicians United States; Politicians Wyoming Description An account of the resource This is a collection of 86 photographs of U.S. Senator Alan K. Simpson that were created and used by the Casper Star-Tribune. These photographs are part of a larger collection that consists of photographs and negatives created and used by the Casper Star Tribune from 1967 until the middle of 1995 according to a newspaper article on the donation from February of 2000. Images in this collection may support the use of other collections in the repository or vice versa. Type The nature or genre of the resource Image Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2000.01_PeoplePhotos_AlanSimpson Format The file format, physical medium, or dimensions of the resource JPG Source A related resource from which the described resource is derived Casper Star-Tribune People Photographs, NCA 01.ii.2001.01 WyCaC US. Casper College Archives and Special Collections. Date A point or period of time associated with an event in the lifecycle of the resource 1981-1993 Provenance A statement of any changes in ownership and custody of the resource since its creation that are significant for its authenticity, integrity, and interpretation. The statement may include a description of any changes successive custodians made to the resource. The Casper Star-Tribune gifted 20 years of photographic negatives and prints to Casper College early in the year 2000. These photographs and negatives have been managed by the Casper College Archives and Special Collections housed in its Western History Center. Date Created Date of creation of the resource. 1981-1993 Relation A related resource <a href="https://caspercollege.cvlcollections.org/collections/show/27" target="_blank" rel="noreferrer noopener">https://caspercollege.cvlcollections.org/collections/show/27</a><br /><br />The finding aid for these and other items in this collection is available for viewing: <a href="https://caspercollegearchives.libraryhost.com/repositories/2/archival_objects/25384" target="_blank" rel="noreferrer noopener">https://caspercollegearchives.libraryhost.com/repositories/2/archival_objects/25384</a> Still Image A static visual representation. Examples include paintings, drawings, graphic designs, plans and maps. Recommended best practice is to assign the type Text to images of textual materials. Original Format The type of object, such as painting, sculpture, paper, photo, and additional data Photographic print Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Al Shares a Laugh Rights Information about rights held in and over the resource <a href="http://rightsstatements.org/vocab/InC/1.0/">http://rightsstatements.org/vocab/InC/1.0/</a> Access Rights Information about who can access the resource or an indication of its security status. Access Rights may include information regarding access or restrictions based on privacy, security, or other policies. Archivists are happy to assist anyone with accessing the physical or electronic copies of photographs. The Casper College Goodstein Foundation Library is glad to grant uses of this material that it actively manages and cares for and will provide its publication policy upon request. Date Created Date of creation of the resource. 1981-10-30 Description An account of the resource Alan Simpson shares laugh with fellow Republican at rally. This photograph is part of a collection of photographs of U.S. Senator Alan K. Simpson that were created and used by the Casper Star-Tribune. They date from 1981 to 1993. These photographs are part of a collection that consists of photographs and negatives created and used by the Casper Star Tribune from 1967 until the middle of 1995 according to a newspaper article on the donation from February of 2000. In the words of Special Collections Curator, Kevin Anderson, the photographs in this collection serve to document "events in our own lives, events in our own history." There were 19,000 envelopes that were gifted to the repository, which totaled between 330,000 and 460,000 images. Images in this collection may support the use of other collections in the repository or vice versa. Type The nature or genre of the resource Image Creator An entity primarily responsible for making the resource Casper Star-Tribune Identifier An unambiguous reference to the resource within a given context NCA 01.ii.2000.01_PeP_AlanSimpson_1981_SharesaLaugh Format The file format, physical medium, or dimensions of the resource JPG Relation A related resource <a href="https://caspercollege.cvlcollections.org/collections/show/26" title="Casper Star-Tribune People Photographs">https://caspercollege.cvlcollections.org/collections/show/26</a> Subject The topic of the resource Politicians United States; Politicians Wyoming Is Part Of A related resource in which the described resource is physically or logically included. Casper Star-Tribune People Photographs, NCA 01.ii.2001.01 WyCaC US. Casper College Archives and Special Collections. Provenance A statement of any changes in ownership and custody of the resource since its creation that are significant for its authenticity, integrity, and interpretation. The statement may include a description of any changes successive custodians made to the resource. The Casper Star-Tribune gifted 20 years of photographic negatives and prints to Casper College early in the year 2000. These photographs and negatives have been managed by the Casper College Archives and Special Collections housed in its Western History Center.